Can someone please explain when you should use a general, refinancing, and no rescission notice?

The big question involves a refinancing and no rescission notice. Should a refinancing rescission notice be provided to a customer when they are refinancing a note with new additional money?

Does a rescission notice need to be given for customer's who who are refinancing a note with no new money provided besides recording fees?

Refer to 23f 4 for your answers (Staff Commentary):

http://www.bankersonline.com/regs/226/suppi226-23.html

>New money is rescindable

>No new money except "costs of refinancing" is not rescindable

Does this still apply if you are refinancing an open-end HELOC to a Closed-end Home Equity loan with the same lender? No new money is being given...just taking the existing HELOC balance and converting it to a term loan. The HELOC came due yesterday.

the closed-end commentary would lead me to believe that up-front disclosures (GFE, etc.) would be required but rescission would not since we are refinacing with the same lender and no new money is being given. There is nothing there saying we have to because the loan matured and it's considered "new" - unlike for open-end which would require rescission in this case because the loan came due and we are doing a new "plan"...

Any thougths??? My guess is rescission does not apply, right?