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.

Others say if any variable rate feature is IMPACTED by the modification, it's a refi.

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.
We're all here 'cause we've lost control.