my 2c is that while your fafsa may imply 0 EFC, each school has its own calculation. I suspect that asset is an issue but I believe that would not show up on fafsa. Sometimes, when you appeal, you have to show your monthly income, and monthly expenses, down to auto insurance costs, and utility bills, etc. On that appeals form, it will ask about the any loan (HELOC). Sometimes the FA officers also suspect the worst and it might be a good idea to ask directly. Good luck.