Customer has a fixed rate home loan. We are doing an additional advance and increasing the rate. Not using a new note so it is not a refinance. It is not an ARM with a new variable rate.
Do we have to redisclose and if so, do we base it on just the new money or a blended disclosure for the old and the new money at the new rate?
We will do a notice of right to cancel.

I would ask this question of the legal counsel you have drafting the necessary modifications that will be required to pull this off. This is a very unusual way to handle this and it will all depend on whether under state law the old obligation is replaced.

Turns out the underlying loan is a variable rate (employee loan, rate goes up upon termination) so I feel that new disclosures are necessary under the commentary to 226.20. Customer/employee agrees to the increase in rate on everything so even if a new note is not being used I am recommending we treat it like a refinance with new disclosures.