Not to steal your thread but I too have HELOC concern.
We are looking at issuing a HELOC card that functions like a consumer debit card except that the default POS/purchase account is a line of credit rather than a DDA.
The face of this card will indicate Debit Card.
Since advances are against the LOC, Reg Z applies.
Are others labeling such a card as debit card rather than credit card?
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