We have a construction loan that we need to amortize out for permanent phase. My question is can we just do a change in terms to amortize the loan if we are keeping the interest rate the just moving it to monthly P&I payments.

If you are not adding or changing a variable rate feature or replacing the existing legal obligation, then it would not be a refinance under 1026.20(a).

With that said, some lenders get a little nervous about moving a 12 month interest only loan to a 30 year payout without providing TRID disclosures. Those lenders choose to disclose under TRID regardless.