If the bank is looking at 90-day extension for a customer to complete construction on their home improvements and the bank wanted to charge a fee for the extension, do we have to provide a new set of disclosures? The loan has not matured yet and I don't feel that it would be considered a "refinance" under Regulation Z.

Deferments/extensions are governed by state law. As long as your state law does not prohibit the fee you would disclose the fee in your extension agreement. This would not be a refinance under Reg. Z.

Okay, thank you Dan.