Official Interpretation
20(a) Refinancings
1. Definition. A refinancing is a new transaction requiring a complete new set of disclosures. Whether a refinancing has occurred is determined by reference to whether the original obligation has been satisfied or extinguished and replaced by a new obligation, based on the parties' contract and applicable law.
If you modified the existing obligation, it was not extinguished "and" replaced.
Then refer to Comment 3, which you say you did not do.
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