Could someone please tell me, If we are doing a HELOC on customer's primary residence but the purpose is to purchase investment property, does the ROR apply?

Business purposes loans are exempt from the requirements of Reg. Z.

Unless the borrower is in the business of buying and selling investment property then this would probably qualify as a personal investment and would be a consumer purpose loan and subject to Reg. Z.

If the borrower is purchasing rental property, then the purchase of non-owner occupied rental property is exempt, but the purchase of investment property is not unless you can qualify it under the exemptions of 226.3 and its Commentary.

Thanks, Dan. I thought you might say that.