We need to refinance an open-end HELOC into a closed-end variable rate note. I am thinking that we need to do all ARM TIL disclosures and RESPA, would this be correct?
You are correct. Don't forget Flood (although you may be able to rely on a previous SFHDF), RofR (if new money is advanced) and HMDA (if it is HI or refinance of purchase money, or if you choose to report all refinancings).