Answer:
A by Randy Carey:
Operational issue and not one of compliance.
A by Andy Z:
To expand on what Randy said, it is not a compliance requirement. Reg Z has a test for a renewal/refinance including when one Note replaces an older one, versus a modification which amends an existing Note. Many people believe a new note number is a test but that is not the case. What your loan numbers are and when they change is really up to your bank and has nothing to do with the obligation.
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