I have a loan which is being refinanced with an additional $25000.00. The loan is a HPML and we had an appraisal within the previous 6 months. Our policy is to at least have an in-house evaluation completed to update the appraisal. In this case the loan is a HPML requiring an appraisal.
this is a stretch, but could the $25000.00 exemption be used for this transaction since that is all the new money being borrowed?

No.

2. Qualifying for exemption — in general. A transaction is exempt under § 1026.35(c)(2)(ii) if the creditor makes an extension of credit at consummation that is equal to or below the threshold amount in effect at the time of consummation.