Answer:
If the bank renews or modifies the loan (without satisfying and replacing the original loan agreement), it is not covered by Regulation Z, since Regulation Z does not apply to modifications. If the bank refinances (satisfies and replaces the original agreement,) the ATR/QM rules on the refinance are the same as for the original loan. Regulation Z and state law should be considered when deciding whether a transaction meets the definition of a refinance.
print
share