I have a customer refinancing a commercial-purpose loan that is secured by his personal residence. There is no additional cash out. Am I right in thinking that the original purpose does not matter and that this is now just a re-fi loan that will require all the consumer disclosures? The more I think about it, the more confused I get!

Bump

In my eyes, you still have a commercial loan. Maybe if they were refinancing with extra money to use for a consumer purpose, you could argue the other way, but i don't see where simply refinancing the loan makes a commercial loan suddenly consumer.

Your loan is still a commercial loan. Why do you think the purpose changed? A residence on a commercial loan does not make it a consumer purpose loan, just as a store securing a consumer purpose loan does not make that a commercial loan.