[TheBank]

We have a consumer construction draw down line of credit loan with terms of interest monthly, principal at maturity that has matured. We need to renew the loan and since it has already matured making us not able to do a change in terms agreement to extend the maturity date, we are looking at a renewal possibility that is exempt from TRID.

The definition of refinance in 1026.20 excludes a renewal of a single payment obligation with no change in the original terms. Since interest monthly, balance at maturity meets the definition in the commentary of a single payment obligation, are we able to renew the loan without triggering TRID requirements? If so, what documents would we need? Could we do a note and closing disclosure without timing requirements?

[rcooper]

My understanding is that once the original obligation matures a new transaction would be considered a refinancing and would require new disclosures. I’d suggest you talk to your attorney to assist you with this determination.

[Author]

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