some in bank are arguing that if we have a hard maturity and no obligation to renew/refinance/modify the original, that would make the renewal agreement a new agreement (refinance) and not a modification.
Reg. Z 1026.20(a) identifies what a refinancing is for redisclosure purposes.
If there is disagreement among bank personnel if the transaction is a refinancing or a modification then your best course of action is to get your legal counsel involved.
I just realized this is open-end credit so you will need to refer to 1026.9.
Last edited by Dan Persfull; 07/20/22 04:39 PM.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.