Say we have a rate locked on 01/01/14 for 45 days and QM pulls the APOR for that date. Then on 02/13/14, we do a 15-day rate extension with a fee due to current lower rates. Does the APR still compare to the initial APOR given on 01/01, or should it pull the most recent APOR as of 02/13? What if there was no fee and pricing stayed the same?

I see in the commentary in section 35, section 43, and section 32 that they all say the same thing.
"2. Rate set. A transaction's annual percentage rate is compared to the average prime offer rate as of the date the transaction's interest rate is set (or "locked") before consummation. Sometimes a creditor sets the interest rate initially and then re-sets it at a different level before consummation. The creditor should use the last date the interest rate is set before consummation."

So we are questioning the "...at a different level..." Does "level" refer to the rate itself or the pricing of the rate?

It is the last date on which the interest rate was set. If you re-lock, IMHO it is that date.

If we have a rate renegotiation, where we're changing rate and pricing, we would definitely use the new lock date. But if we're just extending the current lock, is that considered a "re-lock"?