Hello all - hoping to get some input here. Have an adjustable rate home equity loan (closed end), borrower is requesting to change it to a fixed rate. This can be accomplished through a change in terms, correct? I've read through 1026.20 as far as what would be considered a refinancing and since we are not adding a variable feature, but changing to a fixed rate, we should be able to accomplish this through a change in terms, correct? The part that I am doubting is that the change will actually increase the rate (at least initially), so is that an issue?

Thanks for any input.