HELOC Reg. B Government Monitoring Information

If a customer is using his HELOC's initial draw to payoff a portion his original note, while the remaining payoff will be refinanced into the secondary market, is the Reg. B Gov't Monitoring Info required to be reported for the HELOC? Under 02.13(a)(6) commentary "satisfied and replaced" seems to be replacing one obligation with another obligation. Here, the HELOC will pay down the original loan, with the majority of funds being refinanced into the secondary market.

Would the HELOC's primary purpose under the commentary for 02.13(a)(5) would be a "refinance" in this case? Here, it doesn't appear "readily apparent." Thank you.

If they are simultaneous closings then both loans are satisfying and replacing the original loan.

Yes, the closings were at the same time. Thank you.