We are renewing a loan that was originally to purchase the borrowers primary residence. The loan has matured and is now rental property, no new money is being advanced ... Is the renewal still subject to Reg Z and RESPA?

renew or refinance?

We are renewing the loan with new loan documents.

The unboled part of your statement = renewal.
The bolded and underlined part = refinance.
Read this and see if it answers your questions.

ok, I meant refinancing. My main question is the original money was consumer purpose, this "refinance" does not change that. But as far as a reg z exemption (purchase, improve, maintain non-occupied rental property)it does not fit, but today the home is non-owner occupied rental property. My loan officer does not get my argument, so i wanted support that it is still the refinance of consumer debt and not a commercial non-disclosable loan.

Try reading this guru comment on it.

Hope it helps!

I wanted to come in and clarify that as Joker points out here rental properties are exempt from Reg Z and RESPA.
I hope the links help you with the back-up you needed for your LO.