You should go back to them and ask them to provide the support for their position.
1026.20(c) is only triggered " in connection with the adjustment of interest rates pursuant to the loan contract". No interest rate change = no notice or re-amortization of the existing loan.
1026.20(c) Rate adjustments with a corresponding change in payment. The creditor, assignee, or servicer of an adjustable-rate mortgage shall provide consumers with disclosures, as described in this paragraph (c), in connection with the adjustment of interest rates pursuant to the loan contract that results in a corresponding adjustment to the payment.
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