Answer:
We'll see if other Gurus have an opinion on this, but the rate reduction is not a refinancing and no new disclosures are required because of that. If the fee is a buy-down though, I view that as a direct consumer cost related to the finance charge and that makes this a cloudy issue at best. I would be conservative and treat this cost as a new loan/refi and make disclosures. Even with the eventual lower rate, you are imposing a new fee. I have not seen a case directly on this point, however.
First published on BankersOnline.com 7/15/13