Yes.In reviewing the final student loan regulations released by the Federal Reserve on August 14, 2009, the following is found in the discussion within the preamble to the regulations.
“The final rules require a complete disclosure at the time the credit is extended. In addition, new disclosures are required under § 226.20(a) in the case of a refinancing of a loan.”
So, unfortunately, the refinancing of any current loan will fall under all the new student loan requirements, which will include the application disclosures, the pre-closing disclosures and the final disclosures at loan closing along with the right of rescission.
The opinions expressed are my own, take them or leave them.