[adregne]

Previously under Reg Z, if the customer was not receiving more money at the time of renewal they did not receive any early disclosures. Is that still true?

Also, since the customer will be receiving the Closing Disclosure, does that have to be delivered 3 days before closing even though there are no closing costs?

[rcooper]

You will still look to 1026.20(a) to determine if you have a refinance. If so that is considered a new transaction requiring new disclosures within the time frames outlined in 1026.19.

Here are a couple of recent question on determining a refinance:

Refi or Modify Matured Note

TRID – Refinance or Home Equity?

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