You probably need to have a conversation with your legal counsel to make the determination on whether your process and documentation constitute a "satisfaction and replacement" or not. If it constitutes a "satisfaction and replacement", then it will be a refinance under 1026.20 and will require new disclosures. Keep in mind UDAAP too - even if Reg Z does not technically require new disclosures, can a case be made that the consumer did not get important information to make an informed decision?
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions