How are renewals to be treated after 10/3/2015? Are they to go through the same process?

In order to answer your question I would need to know what you mean by "renewal". Are you taking Loan A and tearing it up and replacing it with Loan B or are you taking Loan A and simply modifying it in some fashion (i.e. extending the existing maturity date)? If modifying, exactly what terms will you be modifying? If your're tearing up and replacing and this occurs on or after 10/3 it's under the TRID umbrella.

We would be modifying loan A. We would not replace loan A with loan B. Mostly we would be extending the maturity date.

You will quite likely be able to avoid TRID in this scenario. However, any answer cannot be final until "mostly" is fully explained. So as not to make an error.

Let's say, then, that a rate might be adjusted (up) or money added (ROR) but done by modification to the original note, rather than replacement.

How would you answer that, Jerod??

FYI - Compliance 1 Mortgage is currently telling us they consider renewals a new loan and therefore subject to TRID. Have not had time to test what will happen if you try. I assume when you start to input it will pull you over to C1 Mortgage but not sure. Just wanted to share the frustration

I'd go camp out in 1026.20(a) and the commentary and then get back to you:)

If you are marking inside C-1 Lending that it is a 'renewal', it will compute as a replacement. You would have to mark it as a modification.

I tested the difference between 'renewal' and 'refinance' at one point and there is some slight language difference in the note between the two...but it does produce a new note...not a modification to the existing one.