We are having a debate about whether or not a renewal is an "extension of credit" if the loan amount will not be increase. At our institution, a revolving line of credit or balloon note is renewed at maturity for similar terms. Basically, the maturity is extended for 12 months. Would this type of transaction fall under the bold sentence below from the definitions in Reg B?

1002.2(f)
(f) Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. The term application does not include the use of an account or line of credit to obtain an amount of credit that is within a previously established credit limit. A completed application means an application in connection with which a creditor has received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested (including, but not limited to, credit reports, any additional information requested from the applicant, and any approvals or reports by governmental agencies or other persons that are necessary to guarantee, insure, or provide security for the credit or collateral). The creditor shall exercise reasonable diligence in obtaining such information.

I am not sure what a loan extension has to do with that sentence. That extends the legal obligation of a current credit extension, not to obtain an amount under a current credit extension.

If loan A matures on November 22, 2022, and the borrower requests that the loan be renewed or extended, that's an application for credit. You need to look at the definition of "credit" in the regulation, too. It's "the right granted by a creditor to an applicant to defer payment of a debt, incur debt and defer its payment, or purchase property or services and defer payment therefor."

The bold text is what renewal or extension of a loan is all about.

Strictly speaking, the renewal is not an application. But in most cases, a renewal or extension doesn't occur unless it's requested by the borrower. The request is an application for credit.