I have reaad Reg. Z 226.20 and still I question...Is it possible to renew and extend a consumer mortgage and modify the interest rate from fixed to adjustable? The existing obligation would not be replaced, the rate (initially at least)would be lower. It would be a renewal of a single payment obligation but the original terms would be changing which is what makes me think it would have to be treated as a refinance and not renewal. Any input would be appreciated?

.Is it possible to renew and extend a consumer mortgage and modify the interest rate from fixed to adjustable?

No. Any addition of a variable feature that was not previously disclosed is a refinancing and requires all new disclosure.

From the Commentary to 226.20.

Even if it is not accomplished by the cancellation of the old obligation and substitution of a new one, a new transaction subject to new disclosures results if the creditor either:

Adds a variable-rate feature to the obligation.