We offer a loan on deposit (secured by CD) product which has a stated term of 12 months. At the end of the 12 months the borrower may extend the maturity for another 12 months. Do we need to provide new disclosures for the extension?

If the extension does not replace the original obligation and there are no other change of terms that would classify it as a refinancing - no.

Thank you rlCarey, that is what i was concerned about. 226.20(a) provides for an exception to the definition of a refinance if the interest rate is decreased. But if the rate is increased we will have to re-disclose. Can we just disclose a fed box and payment stream or would a new note be required? Also, since this loan does not meat the requirement of a variable rate adjustment (226.20(c)) are there any timing requirements for new disclosures?