Bringing this thread back to "life" a bit. I believe the answer is here, but, let's say you have a bank that only does HPML mortgages, but they lost their small creditor exemption because they failed to originate any covered transactions during the "look-back" period. When the balloon loan is coming up on maturity, if it is a "refinance" as defined by Reg. Z, then the bank would be required to comply with the HPML escrow rules. However, if the Bank "renews" the loan in a manner that does not constitute a refinance, then they are not required to comply with the HPML escrow rules and just "keep it moving. Correct?