Sounds like a HELOC is being used as a bridge loan which would imply the FI cannot reasonably contemplate repeated transactions. I would be more concerned with the following in 1026.43:
(h) Evasion; open-end credit. In connection with credit secured by a consumer's dwelling that does not meet the definition of open-end credit in § 1026.2(a)(20), a creditor shall not structure the loan as an open-end plan to evade the requirements of this section.
Official Interpretation
43(h) Evasion; open-end credit.
1. Subject to closed-end credit rules. Where a creditor documents a loan as open-end credit but the features and terms, or other circumstances, demonstrate that the loan does not meet the definition of open-end credit in § 1026.2(a)(20), the loan is subject to the rules for closed-end credit, including § 1026.43.
However to answer your question IMO you report it as the principal residence securing the HELOC.
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The opinions expressed are mine and they are not to be taken as legal advice.