In Texas we don't have HELOCs but the criteria below are triggering terms for open end credit and you are no where close to these.
§226.16 Advertising.
(b) Advertisement of terms that require additional disclosures. If any of the terms required to be disclosed under §226.6 is set forth in an advertisement, the advertisement shall also clearly and conspicuously set forth the following: 36d
(1) Any minimum, fixed, transaction, activity or similar charge that could be imposed.
(2) Any periodic rate that may be applied expressed as an annual percentage rate as determined under §226.14(b). If the plan provides for a variable periodic rate, that fact shall be disclosed.
(3) Any membership or participation fee that could be imposed.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell