converting a temporary home purchase to perm financing. Not a const/perm loan. This would be a refinancing.
The fact you do not meet the threshold for reporting HELOCs has no bearing if the closed-end loan is covered. You are satisfying and replacing an existing dwelling secured loan (assuming the "investment" properties are dwellings) with assumably a new dwelling secured loan and to the same borrower. This would be a refinancing.
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The opinions expressed are mine and they are not to be taken as legal advice.