I agree this does not make sense per the new definition of a refinance.
The only thing I can think that they are falling back on is in the GIR every reference I found to HELOCs stated to report the amount for HI or home purchase. There was no mention of refinancings, but as we agree, the definition of a refinance should include these HELOCs.
We do not report HELOCs because the dollar amount reporting requirements leaves too much margin for error.