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Renewing Existing RLOC and Adding New Money

When renewing an existing RLOC and adding new money, do you need to payoff the existing line and give it a new loan number since you are increasing the loan amount or can you use the same loan number and renew and increase the existing RLOC using the same loan number?

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.

First published on 05/10/2020

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