We are originating a refinance loan for a customer to replace an existing mortgage with another lender. There is no new money being extended. As I understand Reg. Z, since there is no new money the ROR does not apply. Can anyone confirm or correct my thoughts here???

No - since a new creditor is involved the RofR will apply. The exception only applies if it is the same creditor.

Thanks for clarifying, Randy! I just found that in the commentary as well:

4. New advances. The exemption in §226.23(f)(2) applies only to refinancings (including consolidations) by the original creditor. The original creditor is the creditor to whom the written agreement was initially made payable.

Is this still the case if we are the original lender in a purchase transaction (no rescission given initially) and we are renewing the loan for 30 days - no new money, no rate change, no change in terms - I would not consider this a refinance. However, even if it is coinsidered a refi, is rescission applicable given the fact that they haven't ever been given the chance to rescind? Or can I can follow the no rescission rule because it meets the defition of refiance.

As long as you are the original creditor and there is no new money being disbursed with the new transaction then the ROR does not apply regardless what the purpose of the obligation being refinanced was.

thanks Dan!