You are correct. See §1026.23(f)(2).
Refi Not Rescindable if No New Money/Same Lender?
I have a closed-end transaction secured by a principal dwelling which is being refinanced to another closed-end product (no new money). The original transaction provided a right of rescission. Please confirm that the refinance loan is not rescindable since it is with the same lender and no new money is being funded. I can't find a cite for this.
First published on 03/24/2019