We are not aware of any laws or regulations that require you to provide specific disclosures when renewing a mortgage loan (versus refinancing a mortgage loan, which would require new TILA and RESPA disclosures). We do recommend consulting with your bank counsel when creating the loan renewal agreement and any other legal documents.

In addition, we are not aware of any limitations on charging an appraisal fee when renewing a mortgage loan. For example, Regulation B expressly permits creditors to charge “a reasonable fee to reimburse the creditor for the cost of the appraisal or other written valuation unless otherwise provided by law,” and we are not aware of a prohibition on charging an appraisal fee in this context.

For resources related to our guidance, please see:

• Regulation Z, 12 CFR 1026.23(f)(2) (“The right to rescind does not apply to the following: . . . (2) A refinancing or consolidation by the same creditor of an extension of credit already secured by the consumer’s principal dwelling. The right of rescission shall apply, however, to the extent the new amount financed exceeds the unpaid principal balance, any earned unpaid finance charge on the existing debt, and amounts attributed solely to the costs of the refinancing or consolidation. . . .”)

• Regulation B, 12 CFR 1002.14(a)(3) (“A creditor shall not charge an applicant for providing a copy of appraisals and other written valuations as required under this section, but may require applicants to pay a reasonable fee to reimburse the creditor for the cost of the appraisal or other written valuation unless otherwise provided by law.”)