When refinancing a HELOC at maturity, we do not provide rescission if the commitment amount is not increasing. We have done it this way for years, and it has never been raised as an issue with examiners (our most recent FDIC exam was a year ago). In reading 1026.15, however, it appears that we should be providing rescission, even if the commitment amount does not increase. Can anyone give me any insight on this? Thank you!

There is no refinancing by the same creditor exception to the right of rescission in the open-end credit rules.

Maybe review 1026.15. Comment 15 (a)(1) in particular. Randy is right (of course) there is no exception for refi on a HELOC like there is on a closed-end loan. However, I think a Notice of Right of Recission is still necessary.
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