This is a pet peeve of mine.
1. Why would you price a business purpose RLOC as a consumer HELOC?
2. Why would you use a consumer HELOC legal agreement that restricts your ability to freeze or terminate the LOC? You are giving the borrower regulatory protections they are not entitled to under the regulations.
Outside of that there is no regulatory restrictions for processing it through your consumer HELOC program that I am aware of.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.