Calif. Financial Code 22330 states a Finance Lender cannot take a deed of trust, mortgage or lien on real porperty for a consumer loan of a bona fide principal amount of less than $5,000. Wouldn't this mean a HELOC must require an INITIAL minimum draw of at least $5,000? Otherwise a LOC without a draw would not qualify as having the "bona fide principal amount" and would thereby not be eligible for lien filing. Thoughts??