Converting a HELOC to a closed-end HE is a refinancing and you must follow all the closed-end disclosure rules from the date of the application/request to convert the loan which includes Regulation X § 1024.7, and Regulation Z §§ 1026.19(a), 1026.19(b) if a closed-end variable rate loan, 1026.32, .35 and .43, flood requirements, HMDA, etc. ..... I think you can see where I'm going.
If no GFE was provided then you will have to run your comparison chart with $0 in the GFE column and the actual charges in the HUD column and make the applicable cures. Based on your comments I would venture a guess you may have several cures that need to be made, and you could also have possible Reg. Z violations if proper Reg. Z disclosures were not made.