Everyone of BOL has been so helpful in the past that I hope you can help me with the following questions.

I understand that workout loans are not refinances under Reg. Z unless the APR is increased or additional credit is advanced beyone amounts already accrued plus insurance premiums. It is my understanding that workouts are usually done on delinquent loans. I have a couple of questions that I hope you can help me with:

Is a hardship modification where the loan is not delinquent at the time of modification also considered a workout under Reg. Z?

If the hardship modification is not considered a workout and after a certain number of months, it returns to the original APR and the maturity date is extended (but there is no new note), is this considered a refinance under Reg. Z Commentary 226.20(a)(2)(2) "Corresponding change...The exception in 226.20(a)(2) does not apply if the maturity is legthened, or if the payment amunt or number of payments is increased beyond that remaining on the existing transaction"?

Bump. Please.

Bump. Still no takers? (sigh)

I would like to bring the following up again:

Is a hardship modification where the loan is not delinquent at the time of modification also considered a workout under Reg. Z?

A modification in any form that's not replacing the original note does not carry disclosure requirements unless you are adding a VR feature.

(If that's the reason for your question. Also, if you are lowering rate/payments to help someone out, it's exempt from the refi disclosure similary to work-outs)

Yes, it does.

Thanks.