Consumer Loan Modification

If we're modifying a consumer loan by extending the maturity date, adding a voluntary escrow (it's a mobile home loan), therefore changing the payment - would we have to redisclose a new Truth in Lending disclosure to the customer?

It techinically doesn't meet the definition of a refi, so my gut is telling me no...

Unless you are satisfying the old note and replacing it with a new one (or adding a variable rate feature), no.