I've been reading old threads all morning, and there seems to be conflicting opinions on when a modification on an ARM needs new disclosures (that is, treated as a refi under Reg. Z).

Some say that new disclosures don't need to be given unless an variable rate feature is ADDED.
http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1922405
http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1916940

Others say if any variable rate feature is IMPACTED by the modification, it's a refi.
http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1674442

I've been scouring 1026.20 and its commentary and I'm confused. If anyone could offer some assitance I'd greatly appreciate it. The situation here is a lender wishing to extend the fixed rate period with no other changes to the loan. So, we aren't adding a variable rate feature, but I'd think extending the rate period definitely impacts the variable rate features disclosed originally. Does anyone have any thoughts?

Thank you again.
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