12CFR226.20(a) requires redisclosure if the creditor increases the rate based on a variable rate feature that was not previously disclosed. We have a renewal of a construction loan to an individual that is going from a fixed rate to a variable rate, so we need to give a new TIL. Do you include the original prepaid finance charges disclosed on the original TIL? This is not addressed. Logic says yes, but I've missed the boat using logic before.

No, it's a totally new and separate transaction.

Thank you! You have saved me a lot of research time!