It appears that the renewing of a PEL triggers all of the disclosure requirements for PELs. I am struggling to find it in the regulation. Would someone be able to point me in the right direction as to where it mentions that in Reg Z? Meanwhile ... the search continues

Not sure you will find it, but if it applies to a consolidation loan, why would it not apply to a singe loan refinance?

46(b)(5) Private Education Loan

1. Extended expressly for postsecondary educational expenses. A private education loan is one that is extended expressly for postsecondary educational expenses. The term includes loans extended for postsecondary educational expenses incurred while a student is enrolled in a covered educational institution as well as loans extended to consolidate a consumer's pre-existing private education loans.

What if its a straight renewal with no new money, no new note?

Well, if it not a refinance under 1026.20, then it would not be subject to Reg. Z.

Super. Thank you.