You'll find two schools of thought on this, but i'd report it as a refinance (assuming there is no new money with the new loan) as i see nothing in Reg. C or the GIR that would indicate any other reporting purpose.
ETA: this is also assuming that your loan isn't two-phase, which from your post seems to be a correct assumption.
Last edited by raitchjay; 02/11/14 09:19 PM.
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I'm fixin' to fix that.