We typically treat an increase to a credit card or line of credit as new credit. Would MLA apply to an increase whether or not a lender treats an increase as new credit?

I would ask, is there a new credit agreement? The spirit and intent of the MLA is to protect the borrower from certain terms and if your new agreement has or may have those terms, I would opine it does. Loans here are those covered by Reg Z, with some exceptions.

The MLA Regs at 32 CFR 232.6(e) stipulate that the refinancing or renewal of consumer credit requires new MLA disclosures only when the transaction for that credit would be considered a new transaction requiring disclosures under Reg Z. You can find the Reg Z rules for open-end credit at 1026.9 and for closed-end credit at 1026.20(a). The rules for open-end credit are not as clear as for closed-end. As Andy says, if you are giving them a new agreement, I would absolutely err on the side of caution and provide MLA disclosures as well if it is a covered borrower.

Thank you Andy and BeechFlyboy! Your responses make sense when a new agreement is required for the increase.