Anything you do after maturity - regardless of what your attorney says is a new plan under Reg. Z and triggers all disclosures.
Section 1026.40—Requirements for Home-Equity Plans
2. Changes to home equity plans entered into on or after November 7, 1989. Section 1026.9(c) applies if, by written agreement under §1026.40(f)(3)(iii), a creditor changes the terms of a home equity plan—entered into on or after November 7, 1989—at or before its scheduled expiration, for example, by renewing a plan on different terms. A new plan results, however, if the plan is renewed (with or without changes to the terms) after the scheduled expiration. The new plan is subject to all open-end credit rules, including §§1026.6, 1026.15, and 1026.40.
The opinions expressed here should not be construed to be those of my employer: PPDocs.com