I haven't read the 10/8/13 document in its entirety but what I have read it does encompass HELOCs in a first lien position and it would also encompass HELOCs in a subordinate lien position if the first lien holder is not escrowing for the flood insurance premium or is exempt and the subordinate lien holder is not exempt.
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The opinions expressed are mine and they are not to be taken as legal advice.