Well, for overall compliance reasons, this timid person would think it better to just redisclose as a standard practice when renewing or paying off but this is from the OCC handbook:
When an obligation is satisfied and replaced by a new obligation to the original financial institution (or a holder or servicer of the original obligation) and is undertaken by the same consumer, it must be treated as a refinancing for which a complete set of new disclosures must be furnished. (some text cut) In any form, the new obligation must completely replace the earlier one to be considered a refinancing under the regulation. The finance charge on the new disclosure must include any unearned portion of the old finance charge that is not credited to the existing obligation.
(226.20(a))
The following transactions are not considered refinancings even if the existing obligation is satisfied and replaced by a new obligation undertaken by the same consumer:
• A renewal of an obligation with a single payment of principal and interest or with periodic interest payments and a final payment of principal with no change in the original terms.
• An APR reduction with a corresponding change in the payment schedule.
• An agreement involving a court proceeding.
• Changes in credit terms arising from the consumer’s default or delinquency.
• The renewal of optional insurance purchased by the consumer and added to an existing transaction, if required disclosures were provided for the initial purchase of the insurance.
However, even if it is not accomplished by the cancellation of the old obligation and substitution of a new one, a new transaction subject to new disclosures results if the bank:
• Increases the rate based on a variable rate feature that was not previously disclosed; or
• Adds a variable rate feature to the obligation.
If, at the time a loan is renewed, the rate is increased, the increase is not considered a variable rate feature. It is the cost of renewal, similar to a flat fee, as long as the new rate remains fixed during the remaining life of the loan.
If the original debt is not canceled in connection with such a renewal, the regulation does not require new disclosures. Also, changing the index of a variable rate transaction to a comparable index is not considered adding a
variable rate feature to the obligation.
So there are some rules! Page 31. OCC TIL handbook:
http://www.occ.treas.gov/handbook/til.pdfKathy