Our branches enter applications online, which transmit to underwriting. Under our HELOC product you cannot choose anything but "personal use" for purpose. Now, I understand that Reg B requires GMI be collected for any purchase or refi of a primary residence, including for open-ended lines; But, what if you cannot choose purchase or refi,only personal use. Are we clear of needing GMI on HELOC's under Reg B? Further, what if our conversation log notes indicate that, even though personal was chosen, we knew the proceeds would payoff an existing HELOC elsewhere? GMI required then?