We are doing on RARE occasion loan consolidations, and they were wondering if we need to give the customer a new TIL.

No ROR since there's no new money, but due to the potential rate change and such, I am thinking that a new TIL would be the prudent thing to do.

Unless you are doing the consolidation by a modification agreement you would need to redisclose all the appropriate disclosures, including early disclosures.

A consolidation is not automatically exempt from the ROR. If one of the loans with your FI being consolidated is not currently secured by the primary dwelling then the ROR would apply as that portion would be "new money" (an increase in the security interest) and subject to rescission.