Gigi,
In my experience Helocs are subject to TILA as any loan. However, if the Heloc was concurrently closed with a first mortgage on a purchase, there is no rescission. Typically on purchases there is no 3 day to cancel that is why there will not be a NORTC in your docs. There are limits to the fees that are charged on the entire transaction (1st and 2nd combined) based on Section 32, an Anti-Predatory Lending Law.
You may want to review your loan docs or entertain an audit. I am sorry I couldn't be of much help.
Indymacfighter
