I couldn't find anything that addressed this type of issue, so apologize if I missed it.

1026.20 (2) ) says A reduction in the annual percentage rate with a corresponding change in the payment schedule is not a refinance.

So if I want to modify the rate for a borrower, what is my obligation for other existing borrowers with similar rates and terms?

We are looking to buy one or more mortgage notes from another bank that a new lender had originated while there. The lender wants to lower the rate on one or more of them to the rate we are currently offering on similar quality new or refinanced loans. Must I go through and identify existing similar borrowers and do the same or can I just modify on request?

I was thinking that we could buy it as is and then if the borrower requested a lower rate, we could modify it. Would they need to complete an URLA? Rate is the only thing I am looking at modifying.