FIND THE EXPLANATION
Compare the cost of replacing debts, including the rate after any promotion ends.
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The central test is whether an existing obligation subject to Regulation Z’s closed-end provisions is legally satisfied and completely replaced by a new obligation undertaken by the same consumer. The contract and applicable law determine satisfaction and replacement. The transaction’s label does not decide the question. Five specified exceptions can prevent refinancing treatment even when an old obligation is cancelled and replaced. Separately, the official commentary requires new disclosures for certain changes involving a previously undisclosed or newly added variable-rate feature even without cancellation and replacement. These findings are developed in claims C024–C048 below. ecfr.gov+1
The consequence is a disclosure classification. A transaction classified as a refinancing requires a complete new set of applicable disclosures. A transaction undertaken by someone other than the original creditor, a holder, or a servicer is treated as a new transaction under Regulation Z rather than a refinancing under this particular section. Neither proposition establishes an obligation to offer credit, an approval, affordability, savings, release of another obligor, or extinguishment of a lien. Those limits are addressed in C028–C029, C062–C077. Consumer Financial Protection Bureau+2
This investigation uses primary sources opened for R035. It does not adopt R033 findings.
Access and currentness boundary. The access date for the sources below is October 27, 2026, America/Los_Angeles. The session clock was checked at October 28, 2026, 02:07:41 UTC, corresponding to October 27, 2026, 19:07:41 PDT. The retrieved eCFR compilation stated that Title 12 was current through October 26, 2026; the relevant U.S. Code snapshots stated that they included laws through Public Law 119-121, October 9, 2026. The interval after those respective compilation cutoffs through access is not represented as exhaustively cleared of every intervening enactment, publication, or judicial development. The CFPB’s “current regulation” labels are supporting publication metadata, not independent proof of an unchanged legal history. ecfr.gov+2
Every successful source record below has United States federal jurisdiction and the October 27, 2026 Los Angeles access date stated above.
The current Regulation Z section records are parts of one regulatory instrument and its official interpretations. Different sections, agency HTML presentations, eCFR presentations, and Federal Register versions are not counted as independent corroborating authorities.
For HTML sources, printed-page and zero-based PDF-index fields are not applicable, except where a Federal Register HTML presentation supplies printed-page markers. For the two PDFs used, the read was of parsed text, with the page locations stated below. No PDF pixel, scan, signature, or form inspection is claimed.
| Source ID | Issuer; exact instrument or section | Complete literal HTTPS URLs | Version, actual read extent, and limits |
|---|---|---|---|
| R035-P1-S001 | CFPB, 12 CFR 1026.20, Disclosure requirements regarding post-consummation events; Supplement I, 20(a) Refinancings | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.20 https://www.consumerfinance.gov/rules-policy/regulations/1026/20/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-20/ | Complete §20(a), including (1)–(5), and complete corresponding commentary: general comments 1–5; 20(a)(1)-1; 20(a)(2)-1 and -2; 20(a)(3)-1; 20(a)(4)-1; 20(a)(5)-1. eCFR through October 26, 2026; CFPB labels its presentation current. Other §20 frameworks were not fully investigated. Relevant issuance history is separately recorded in S015–S017. |
| R035-P1-S002 | CFPB, Supplement I to Part 1026—Official Interpretations, Introduction | https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-0/ | Complete substantive introductory comments I-1–I-4 read. Used to identify the official interpretation vehicle and treatment of examples. Full enforcement, defenses, and remedies remain held. |
| R035-P1-S003 | CFPB, §1026.1, Authority, purpose, coverage, organization, enforcement, and liability, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.1 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-1/ | Body (a)–(d), complete relevant coverage commentary under 1(c), and selected organizational/effective-date commentary read. Relied on for general coverage and subpart boundaries, not a complete liability or territorial-law analysis. Current compilation through October 26, 2026. |
| R035-P1-S004 | CFPB, §1026.2, Definitions and rules of construction, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.2 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-2/ | Selected complete definitions: (a)(10)–(14), (17), (20), (22)–(25), (28), and relevant paragraph (b) construction rules. Corresponding material consumer, credit, consummation, creditor, open-end, and prepaid-finance-charge commentary read. The numerical illustration table within creditor commentary did not render; it is not relied on. The operative creditor thresholds and explanatory counting text were read. Part 253, incorporated by (a)(28), was not separately investigated. |
| R035-P1-S005 | CFPB, §1026.3, Exempt transactions, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.3 https://www.consumerfinance.gov/rules-policy/regulations/1026/3/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-3/ | Complete body (a)–(i) read. Material commentary read: 3(a)-1–10; 3(b)-1–3 and -5–7; public-utility, securities-account, home-fuel, student-loan, and 3(h) partial-exemption commentary. Historical/open-end transition material was distinguished from this closed-end investigation. A CFPB parsing omission in (h)(6) was recovered from eCFR. |
| R035-P1-S006 | CFPB, §1026.4, Finance charge, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4 https://www.consumerfinance.gov/rules-policy/regulations/1026/4/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-4/ | Material provisions read: (a); relevant examples in (b); (c)(1), (2), and (7); complete (d)(1)–(4); and (e). Complete 4(d) commentary, including initial-term, unit-cost, single-interest, debt-cancellation/suspension, and telephone-purchase qualifications, read. Relevant 4(a), 4(c)(1), 4(c)(2), 4(c)(7), and 4(e) commentary read. This is not a complete fee/product dossier. |
| R035-P1-S007 | CFPB, §1026.17, General disclosure requirements, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.17 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-17/ | Complete operative body (a)–(h) read; historical student-transition paragraph (i) distinguished. Material commentary on timing, legal obligation, estimates, minor irregularities, multiple parties, subsequent/early changes, mail or telephone requests, and series of sales read. Selected renewable-balloon commentary was read without completing the mortgage framework. |
| R035-P1-S008 | CFPB, §1026.18, Content of disclosures, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.18 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-18/ | Body (a)–(r) and relevant routing language concerning mortgage disclosures read. Complete material general, amount-financed, prepaid-charge, and itemization commentary read; selected remaining commentary used only for identified disclosure categories. Full mortgage payment-summary provisions and mortgage forms remain held. |
| R035-P1-S009 | CFPB, §1026.23, Right of rescission, narrowly selected cross-reference | https://www.consumerfinance.gov/rules-policy/regulations/1026/23/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-23/ | Complete §23(f)(2) and complete comment 23(f)-4 read to distinguish its refinancing-cost calculation and original-creditor/successor rule from §20(a). No complete rescission investigation or rescission eligibility determination. |
| R035-P1-S019 | CFPB, §1026.22, Determination of annual percentage rate, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-22/ | Complete (a)(1)–(3) and corresponding material comments read, including the irregular-transaction definition and qualification for initially regular variable-rate schedules. Used only to support §17(f)’s early-disclosure boundary. Appendix J, computation tables, and full mortgage tolerances were not investigated. |
The complete §20(a) body and commentary are directly available in the retrieved current presentations. The limited §22 read also recovered the previously truncated retrieval. ecfr.gov+3
The following are statutory authorities, rather than CFPB explanatory guidance. The cited OLRC snapshots include laws through Public Law 119-121, October 9, 2026. Individual historical commencement provisions and the entire amendment history were not reconstructed.
| Source ID | Issuer; title | Complete literal HTTPS URL | Actual read bounds and limits |
|---|---|---|---|
| R035-P1-S010 | Congress; OLRC publication, 15 USC 1602—Definitions and rules of construction | https://uscode.house.gov/us/usc/119-121/t15/s1602/ | Relevant definitions in (a)–(j), particularly credit, creditor, consumer purpose, and open-end credit. Specialized mortgage/private-education definitions elsewhere in the section are not treated as completed product frameworks. |
| R035-P1-S011 | Congress; OLRC publication, 15 USC 1603—Exempted transactions | https://uscode.house.gov/us/usc/119-121/t15/s1603/ | Complete numbered operative exemptions (1)–(7) and displayed relevant amendment/indexation notes read. The statutory base amount is distinguished from the adjusted 2026 regulatory threshold. |
| R035-P1-S012 | Congress; OLRC publication, 15 USC 1605—Determination of finance charge | https://uscode.house.gov/us/usc/119-121/t15/s1605/ | Operative body and displayed notes read; reliance limited to general finance-charge, insurance, property-insurance, and specified security-charge provisions. Full mortgage tolerance/remedy analysis excluded. |
| R035-P1-S013 | Congress; OLRC publication, 15 USC 1638—Transactions other than under an open end credit plan | https://uscode.house.gov/us/usc/119-121/t15/s1638/ | Paragraph (a), including the applicable disclosure categories, and (b)(1) read. Reliance principally on (a)(1)–(13) and the general before-extension disclosure requirement. Later specialized mortgage provisions were not fully investigated. |
| R035-P1-S014 | Congress; OLRC publication, 12 USC 5519—Exclusion for auto dealers | https://uscode.house.gov/us/usc/119-121/t12/s5519/ | Complete (a)–(f) and displayed effective-date note read for the actor boundary incorporated by §1026.1(c). No dealer, licensing, business, or entity lookup; no full investigation of Board Regulation Z, Part 226. |
| Source ID | Issuer; exact title and publication | Complete literal HTTPS URLs | Status, dates, exact read extent, and page/index limits |
|---|---|---|---|
| R035-P1-S015 | CFPB, Truth in Lending (Regulation Z), 76 FR 79768 | https://www.federalregister.gov/documents/2011/12/22/2011-31715/truth-in-lending-regulation-z | Historical interim final recodification; published December 22, 2011, effective December 30, 2011. Read header, summary, dates, transfer/recodification explanation, and historical complete §20(a) commentary. Rule text begins at printed p. 79772; relevant historical commentary at p. 79992. HTML read; no PDF-index claim. This historical issuance does not establish that the commentary remained unchanged. |
| R035-P1-S016 | CFPB, Facilitating the LIBOR Transition (Regulation Z), 86 FR 69716; associated Correction, 87 FR 8733 | https://www.federalregister.gov/documents/2021/12/08/2021-25825/facilitating-the-libor-transition-regulation-z https://www.federalregister.gov/documents/2022/02/16/2022-03344/facilitating-the-libor-transition-regulation-z-correction https://www.consumerfinance.gov/rules-policy/final-rules/facilitating-libor-transition-regulation-z/ | Final rule published December 8, 2021; general effective/compliance date April 1, 2022. Read dates, material closed-end explanation, and complete amended §20(a) commentary, printed p. 69792. Other open-end/appendix transition dates were distinguished. Correction published/effective February 16, 2022; complete correction read: two preamble hyperlinks, not a substantive §20(a) amendment. HTML only. Later §20(a) changes are in S017. |
| R035-P1-S017 | CFPB, Facilitating the LIBOR Transition Consistent With the LIBOR Act (Regulation Z), 88 FR 30598 | https://www.govinfo.gov/content/pkg/FR-2023-05-11/pdf/2023-09129.pdf | Interim final rule with request for comments; published May 11, 2023, effective May 15, 2023. It is an effective issuance, not merely a proposal. Parsed text of selected parts of a 35-page PDF: header/dates p. 30598, index 0; relevant introduction p. 30599, index 1; closed-end explanation pp. 30604–30605, indices 6–7; effective-date discussion p. 30618, index 20; selected amendatory instructions p. 30623, index 25; complete reprinted general §20(a) comments 1–5, pp. 30624–30625, indices 26–27. The five exception comments were read from S001, not assumed from omitted text here. No pixels viewed. |
| R035-P1-S018 | Federal Reserve Board and CFPB, Truth in Lending (Regulation Z), 90 FR 57882 | https://www.federalregister.gov/documents/2025/12/15/2025-22814/truth-in-lending-regulation-z https://www.govinfo.gov/content/pkg/FR-2025-12-15/pdf/2025-22814.pdf https://www.consumerfinance.gov/rules-policy/final-rules/truth-in-lending-regulation-z/ | Final annual threshold rule, published December 15, 2025, effective January 1, 2026. Read header/dates, adjustment explanation, operative 2026 threshold, and material closed-end exemption commentary. Parsed selected text of a 7-page PDF: Reg Z header begins on p. 57882, index 0; explanation p. 57883, index 1; Part 1026 amendatory language and threshold pp. 57886–57887, indices 4–5. Closed-end commentary on printed pp. 57887–57888 also read in HTML. The beginning of PDF index 0 contains preceding material; reliance starts at the Reg Z heading. No pixels viewed. No 2027 threshold is certified by this report. |
These issuance records establish the identified publication and effectiveness events. They are not a representation that every intervening amendment or judicial issue has been independently reviewed. federalregister.gov+4
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C001 | The retrieved eCFR body is a current compilation through October 26, 2026. Its statement that Title 12 was last amended October 23 does not identify the effective date of §20(a). The post-cutoff interval through the October 27 access remains unverified on an exhaustive publication-by-publication basis. | S001, eCFR currency/status notice and §20(a). ecfr.gov |
| R035-P1-C002 | The statutory snapshots used include laws through Public Law 119-121, October 9, 2026. They do not establish exhaustive review of enactments from October 10 through access, or of judicial developments. | S010–S014, OLRC snapshot notices. uscode.house.gov+2 |
| R035-P1-C003 | Supplement I is the CFPB’s published official interpretation vehicle. It should be distinguished from an examiner instruction, agency webpage explanation, circular, or advisory opinion. This report uses the regulation and official interpretations; it does not analyze the full consequences of reliance for liability or defenses. | S002, Introduction I-1–I-4. Consumer Financial Protection Bureau |
| R035-P1-C004 | The CFPB’s 2011 recodification was published December 22 and effective December 30, 2011. Its explanation that the transfer substantially duplicated the existing rule with technical changes is historical; it does not negate later amendments. | S015, summary and dates; historical §20(a) commentary. federalregister.gov+1 |
| R035-P1-C005 | The 2021 LIBOR final rule amended the closed-end official interpretation and generally became effective/compliant April 1, 2022. Its separate open-end notice and appendix transition dates are not alternative effective dates for the current §20(a) test. | S016, dates and §20(a) amendments. federalregister.gov+1 |
| R035-P1-C006 | The February 16, 2022 correction repaired two preamble hyperlinks. It did not create a new substantive §20(a) exception or change its refinancing test. | S016, complete correction. federalregister.gov |
| R035-P1-C007 | The 2023 LIBOR interim final rule, published May 11 and effective May 15, 2023, supplies the material current revisions to the comparable-index discussion, including Board-selected replacements. “Interim final” does not make the text merely proposed. | S017, dates, effective-date section, and amended comment 20(a)-3. govinfo.gov+2 |
| R035-P1-C008 | The annual final rule published December 15, 2025 establishes $73,400 as the §3(b) threshold for January 1–December 31, 2026, effective January 1, 2026. This is a legal coverage threshold, not a transaction amount, credit limit recommendation, or forecast for another year. | S018; S005, comment 3(b)-3.xvii. federalregister.gov+2 |
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C009 | General Regulation Z coverage concerns credit offered or extended to consumers, regularly, subject to a finance charge or payable by written agreement in more than four installments, and primarily for personal, family, or household purposes. The creditor definition excludes a downpayment from that installment count. Specialized card and other provisions can have different scope; the four conditions are not a universal description of every provision in Regulation Z. | S003, §1(c)(1), (d); S004, §2(a)(17)(i). ecfr.gov+1 |
| R035-P1-C010 | “Credit” concerns the right to defer paying debt, or to incur debt and defer payment. A debt’s existence, a request for accommodation, or a label alone does not establish that a new credit transaction has been consummated. | S004, §2(a)(14), corresponding commentary; S010, §1602(f). ecfr.gov+2 |
| R035-P1-C011 | The ordinary consumer definition covers a cardholder or natural person to whom consumer credit is offered or extended. Guarantors, endorsers, and sureties generally are not consumers for ordinary purposes, subject to specified card/rescission contexts. The express confirmed-successor expansion covers §§20(c)–(e), 36(c), 39, and 41; it does not automatically establish §20(a)’s same-consumer predicate. Liability assumed under applicable law can affect other protections. | S004, §2(a)(11); comments 2(a)(11)-1–4. ecfr.gov+1 |
| R035-P1-C012 | Consumer credit requires a primary personal, family, or household purpose. The commentary supplies no single precise primary-purpose test. Certain consumer-purpose tax/estate-planning trusts and land trusts are treated as natural-person credit under the specified trust commentary; an organizational label alone does not resolve those cases. | S004, §2(a)(12), comments 2(a)(11)-3 and 2(a)(12)-1; S005, comment 3(a)-10; S010, §1602(i). Consumer Financial Protection Bureau+2 |
| R035-P1-C013 | Closed-end consumer credit is consumer credit that does not satisfy the open-end definition. Open-end credit requires a plan under which the creditor reasonably contemplates repeated transactions, may impose a finance charge from time to time on an unpaid balance, and generally makes credit available again as outstanding balances are repaid. All three elements matter. Actual repeated borrowing by every consumer is unnecessary; a finite series of advances is not automatically a replenishing plan. | S004, §2(a)(10), (20); complete comments 2(a)(20)-1–7. ecfr.gov+2 |
| R035-P1-C014 | The ordinary creditor test combines regular extension of qualifying consumer credit with the obligation being initially payable to that person, on the instrument or by agreement if no instrument exists. An assignment does not by itself change to whom the obligation was initially payable. This definition must be kept separate from §20(a)’s express inclusion of a holder or servicer. | S004, §2(a)(17)(i) and corresponding commentary; S010, §1602(g). ecfr.gov+2 |
| R035-P1-C015 | Ordinary regularity uses more than 25 qualifying extensions in the preceding calendar year, or more than five for dwelling-secured transactions. If the preceding-year standard was not met, the current calendar year is used. A separate rule covers more than one §32 extension in any 12-month period, or one or more such extensions through a mortgage broker. Special card-issuer provisions also exist. These are transaction/actor coverage tests, not renewal limits under §20(a). | S004, §2(a)(17)(iv)–(v), relevant counting commentary. ecfr.gov+1 |
| R035-P1-C016 | Business, commercial, agricultural, and specified organizational credit are excluded under §3(a). For credit financing an acquisition, the purpose commentary identifies occupation relationship, personal management, acquisition income relative to total income, transaction size, and stated purpose. Collateral’s personal character does not establish consumer purpose. Organizational credit is generally excluded even with a natural-person guarantor or security provider, subject to the trust qualification in C012. Rental-property purpose rules have additional predicates and are not reduced to a universal owner-occupied/consumer rule here. | S005, §3(a), comments 3(a)-1, -3–5, -8–10; S011, §1603(1). Consumer Financial Protection Bureau+2 |
| R035-P1-C017 | Formerly exempt business credit rewritten for consumer purposes requires consumer disclosures under the commentary only when the existing obligation is satisfied and replaced by a new consumer-purpose obligation undertaken by the same obligor, subject to the remaining coverage/exemption rules. Because the old business obligation was exempt, this is a distinct coverage issue; one should not assume §20(a)’s old-covered-obligation predicate. | S005, comment 3(a)-6; S001, §20(a). Consumer Financial Protection Bureau+1 |
| R035-P1-C018 | Part 1026 expressly excludes persons described in CFPA §1029. Section 5519 concerns defined motor-vehicle dealers predominantly engaged in sales and servicing or leasing and servicing, with exceptions for specified mortgage activities, vehicle credit not routinely assigned to an unaffiliated third party, and unrelated consumer-financial activities. It preserves other federal authority. Exclusion from CFPB Part 1026 cannot be equated with exemption from TILA generally; the Board’s Part 226 route remains a separate held inquiry. | S003, §1(c); S014, §5519(a)–(f); S018, agency-authority explanation. ecfr.gov+2 |
| R035-P1-C019 | For closed-end §3(b) coverage, the relevant extension of credit at consummation, or commitment at consummation to extend total credit, must exceed, not merely equal, the threshold then in effect. The exemption does not cover credit secured by any real property, personal property used or expected to be used as the consumer’s principal dwelling, or a defined private education loan. Subsequent paydown or a later threshold increase does not alone remove an exemption established at consummation. The measuring term is credit extended/committed, not an assumed cash-received or amount-financed figure. | S005, §3(b), comments 3(b)-5.i–ii and -7; S011; C008 for the 2026 amount. Consumer Financial Protection Bureau+2 |
| R035-P1-C020 | A replacement loan does not inherit an old loan’s threshold exemption: the new extension must qualify itself. Adding real-property or principal-dwelling security after consummation does not alone remove an existing closed-end loan’s §3(b) exemption, but principal-dwelling security has a separate rescission consequence under the referenced framework. Satisfaction and replacement by a newly secured loan is different: that new loan is not threshold-exempt. No actual security or rescission conclusion is made here. | S005, comments 3(b)-5.ii and -6.ii. Consumer Financial Protection Bureau |
| R035-P1-C021 | Other exemptions require their own conditions: public-utility credit with regulated/filed charges, not ordinary appliance/home-improvement finance; qualifying SEC/CFTC broker-dealer securities or commodities accounts, not every separate securities-purchase loan; qualifying home-fuel budget plans without a finance charge; loans made, insured, or guaranteed under Title IV of the Higher Education Act, not private education loans generally; and qualifying retirement-plan loans drawn from fully vested participant funds in the specified plans and made in compliance with the Internal Revenue Code. No generic “personal loan” label establishes or defeats these exemptions. | S005, §3(c)–(g), corresponding comments; S011, §1603. ecfr.gov+2 |
| R035-P1-C022 | Section 3(h) is a partial disclosure exemption for transactions meeting all its conditions, with an election between specified §18 and §19 disclosures. It does not exempt an otherwise covered transaction from all Regulation Z requirements or independently erase §20(a). Eligibility under its mortgage-assistance conditions remains held. Section 3(i)’s separate valuation provision also prevents treating §3 as a universal exemption from every part of the regulation. | S005, §3(h)–(i), comments 3(h)-1–5. ecfr.gov+1 |
| R035-P1-C023 | Consummation occurs when the consumer becomes contractually obligated on the credit transaction. Applicable state law determines that point. A fee, deposit, preliminary request, or purchase agreement does not necessarily establish credit consummation. No governing jurisdiction or contract is supplied here. | S004, §2(a)(13), comments 2(a)(13)-1–2; §2(b)(3). Consumer Financial Protection Bureau+1 |
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C024 | The general §20(a) test requires an existing obligation that was subject to Subpart C, its satisfaction and replacement, and a new obligation undertaken by the same consumer. The official interpretation requires complete replacement of the prior obligation. All predicates must be established before applying this general classification. | S001, §20(a), comment 20(a)-1. ecfr.gov+1 |
| R035-P1-C025 | Satisfaction/extinguishment and replacement are determined from the contract and applicable law. Consolidation, new-money disbursement to the consumer or on the consumer’s behalf, or rescheduling can be forms of refinancing, but the form or label is not the legal test. “Modification,” “novation,” “rewrite,” “replacement,” “extension,” and similar labels cannot substitute for that inquiry. | S001, comment 20(a)-1; S004, §2(b)(3). Consumer Financial Protection Bureau+1 |
| R035-P1-C026 | Merely changing terms, including deferring individual installments, is not refinancing under the general test without cancellation and substitution. Conversely, a substitution that satisfies the definition can require new disclosures even without a substantial change in credit terms. The separate variable-rate rule in C031 must still be considered. | S001, comment 20(a)-1.i–ii and -3.ii. Consumer Financial Protection Bureau |
| R035-P1-C027 | The five statutory-regulatory exception events in §20(a)(1)–(5) are not treated as refinancings even if accomplished by cancelling the old obligation and substituting a new one. Failure to satisfy one exception is not, alone, a complete affirmative refinancing conclusion: coverage, the general test, other applicable exceptions, and the variable-rate commentary must still be considered. | S001, comment 20(a)-2; §20(a)(1)–(5). The final sentence is the logical application of that structure. Consumer Financial Protection Bureau+1 |
| R035-P1-C028 | Section 20(a) applies to transactions undertaken by the original creditor, a holder, or a servicer of the original obligation. The word “successor” alone does not establish which role exists. The original-creditor/successor rule in the separate rescission commentary must not be substituted for this broader express coverage language. | S001, comment 20(a)-5; S009, comment 23(f)-4. Consumer Financial Protection Bureau+1 |
| R035-P1-C029 | A “refinancing” undertaken by any other person is a new transaction under Regulation Z, rather than refinancing under §20(a). Its coverage and applicable new-transaction disclosures must be evaluated independently. This classification does not establish payoff, closing of the old arrangement, release of an obligor, or lien discharge. | S001, comment 20(a)-5; S003–S005 for coverage. Consumer Financial Protection Bureau+1 |
| R035-P1-C030 | A rate change conforming to a properly disclosed variable-rate feature is not a refinancing. The official example is invocation of such a feature on a renewable balloon-payment mortgage previously disclosed as a variable-rate transaction. The predicates are the prior proper disclosure and conformity of the change; the example supplies no blanket exemption for balloon extensions. | S001, comment 20(a)-3.i; E002. Consumer Financial Protection Bureau |
| R035-P1-C031 | Even without cancelling and replacing the old obligation, a new transaction requiring new disclosures results if the creditor increases the rate using a variable-rate feature not previously disclosed, or adds a variable-rate feature. The comparable-index qualification in C032 limits what counts as adding such a feature. | S001, comment 20(a)-3.ii.A–B. Consumer Financial Protection Bureau |
| R035-P1-C032 | Changing a variable-rate index to a comparable index does not itself add a variable feature, whether replacing an existing index or an index that no longer exists. The current official example treats the 1-, 3-, 6-, and 12-month U.S. dollar LIBOR tenors as comparable to their respective Board-selected consumer-loan benchmark replacements. Section 2(a)(28) supplies the definition; this report does not reconstruct Part 253 or calculate an actual replacement rate. | S001, comment 20(a)-3.ii.B; S004, §2(a)(28); S017; E003. Consumer Financial Protection Bureau+2 |
| R035-P1-C033 | For a proposed LIBOR replacement other than the specified Board-selected replacement, relevant comparability factors are nonexclusive: movements over time, comparable payments if sufficient data exist, index levels, public availability, and independence from creditor control. Historical-data timing may need adjustment when comparing backward-looking and forward-looking rates. The specified Board-selected replacement is deemed comparable for its corresponding tenor, without that factor analysis. | S001, complete comment 20(a)-3.iv. Consumer Financial Protection Bureau |
| R035-P1-C034 | If either C031 event occurs in a transaction secured by a principal dwelling with a term longer than one year, the commentary additionally requires the §19(b) disclosures at that time. That is a precise product/term cross-reference, not a complete ARM-notice or mortgage-disclosure analysis. | S001, comment 20(a)-3.iii. Consumer Financial Protection Bureau |
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C035 | The single-payment exception requires renewal with no change in original terms, subject to the commentary’s specified tolerances. It covers both a single payment of principal and interest and periodic interest payments followed by a final principal payment. It is not an exception for every installment-loan maturity extension. | S001, §20(a)(1), comment 20(a)(1)-1. ecfr.gov+1 |
| R035-P1-C036 | In deciding whether a replacement is a renewal on original terms, the creditor may still treat it as a renewal where accrued unpaid interest is added to principal, changes result from §17(c)(3)’s listed minor factors, or principal is reduced by a curtailment. These specific allowances do not establish a general exemption for any new fee, advance, or capitalized amount. | S001, comment 20(a)(1)-1.i–iii; E005. Consumer Financial Protection Bureau |
| R035-P1-C037 | The incorporated §17(c)(3) factors are: collection in whole cents; changing a scheduled payment/advance date because it is not a business day; differing numbers of days in months; and leap year. The renewal comment cites (c)(3), not every calculation tolerance elsewhere in §17(c). | S007, §17(c)(3)(i)–(iv); S001, comment 20(a)(1)-1.ii. ecfr.gov+1 |
| R035-P1-C038 | The complete §20(a) text and commentary contain no express numerical cap on successive single-payment renewals and no specified elapsed-time allowance for repeated renewals. That textual finding is not unlimited rollover authorization: each event must satisfy the applicable test, and contractual authority and other law remain unresolved. | S001, complete §20(a) and commentary, particularly (1) and general comment -3. ecfr.gov+1 |
| R035-P1-C039 | The APR-reduction exception requires an actual reduction in APR with a corresponding payment-schedule change. The commentary identifies shortening maturity, reducing the payment amount, or reducing the number of payments as corresponding changes implementing the reduction. | S001, §20(a)(2), comments 20(a)(2)-1–2. ecfr.gov+1 |
| R035-P1-C040 | This exception does not apply if maturity is lengthened, or the payment amount or number of payments exceeds what remains on the existing transaction. A lower installment accompanied by a longer maturity therefore does not establish this exception. | S001, comment 20(a)(2)-2. Consumer Financial Protection Bureau |
| R035-P1-C041 | If APR is later increased and the increase is accomplished through satisfaction and replacement, the APR-reduction commentary requires new disclosures even when the increased APR remains below the original APR. The comparison is not simply with the transaction’s first-ever rate. Any independently applicable exception still needs separate consideration. | S001, comment 20(a)(2)-1, read with general comment -2. Consumer Financial Protection Bureau |
| R035-P1-C042 | The court exception concerns an agreement involving a court proceeding. Its official examples include reaffirmations of debts discharged in bankruptcy, settlement agreements, and post-judgment agreements. The court-proceeding predicate cannot be dropped to create a general exception for private settlements or all workouts. | S001, §20(a)(3), comment 20(a)(3)-1; E006. ecfr.gov+1 |
| R035-P1-C043 | The credit definition separately excludes court judgments and court approvals of reaffirmations of debts discharged in bankruptcy. Financing such an obligation by a third party can constitute credit. Thus a court-related arrangement may require both a threshold credit inquiry and, if otherwise relevant, the §20(a)(3) exception inquiry. No bankruptcy or proceeding-specific determination is made. | S004, comment 2(a)(14)-1.ii; S001, comment 20(a)(3)-1. Consumer Financial Protection Bureau+1 |
| R035-P1-C044 | The default/delinquency exception applies to a change in the payment schedule or collateral requirements as a result of the consumer’s default or delinquency. A voluntary hardship request, anticipated difficulty, or use of the word “workout” does not itself establish that causal and status predicate. | S001, §20(a)(4), comment 20(a)(4)-1. ecfr.gov+1 |
| R035-P1-C045 | An increased rate defeats this exception; the official workout commentary expresses the test as an APR increase. It is unsafe to examine only the nominal interest rate while ignoring a fee’s possible effect on APR. The disclosure tolerances in §22 are not an allowance to increase APR while retaining the §20(a)(4) exception. | S001, §20(a)(4), comment 20(a)(4)-1; S019, §22(a). The tolerance distinction follows from the different provisions’ subjects. ecfr.gov+2 |
| R035-P1-C046 | The exception also fails if the new amount financed exceeds the unpaid balance plus earned finance charge plus premiums for continuation of insurance of the types described in §4(d). The commentary summarizes this as additional credit beyond amounts already accrued plus insurance premiums. The measuring amount is not merely new cash delivered to the consumer. The word “continuation” and the §4(d) type limitation must be retained. | S001, §20(a)(4), comment 20(a)(4)-1; S006, §4(d). ecfr.gov+2 |
| R035-P1-C047 | Section 20(a)(4) contains no general “reasonable refinancing costs” addition to that comparison base. Section 23(f)(2) separately addresses rescission for a same-creditor refinancing of credit already secured by the principal dwelling, using unpaid principal, earned unpaid finance charge, and costs attributable solely to refinancing. Comment 23(f)-4 includes qualifying bona fide/reasonable §4(c)(7) fees and other specified non-finance-charge costs in that separate inquiry; it also defines original creditor and specified institutional successors for that purpose. Those rules cannot be imported into §20(a)(4). | S001, §20(a)(4); S009, §23(f)(2), complete comment 23(f)-4. ecfr.gov+2 |
| R035-P1-C048 | The insurance exception requires renewal of optional insurance purchased by the consumer, added to the existing transaction, with the required disclosures relating to the initial purchase having been provided. A charge being called insurance, a new insurance purchase, or evidence only of renewal disclosures does not establish all these conditions. | S001, §20(a)(5), comment 20(a)(5)-1. ecfr.gov+1 |
| R035-P1-C049 | The separate §4(d)(1) finance-charge exclusion for credit life, accident, health, or loss-of-income insurance requires that coverage not be required, written disclosure of that fact and the initial premium, disclosure of a shorter coverage term, and a signed or initialed affirmative request after the disclosures. Any consumer in the transaction may request it. Unit-cost disclosure is permitted only in the specified open-end, §17(g) mail/telephone, or coverage-limited closed-end situations. Optional status is factual; the §4(d)(4) telephone alternative is confined to open-end, non-home-secured plans. | S006, §4(d)(1), (4); comments 4(d)-4–7, -13. These are finance-charge conditions, not additional unwritten conditions added to §20(a)(5). ecfr.gov+2 |
| R035-P1-C050 | For the separate property/liability-insurance exclusion, the consumer must be permitted to choose the insurer and that choice must be disclosed; reasonable-cause rejection of an offered insurer is allowed. If coverage is obtained through the creditor, initial premium and any shorter term must be disclosed, subject to the stated unit-cost limits. Qualifying single-interest insurance additionally requires waiver of subrogation. Nonqualifying extra coverages generally require premium allocation; the commentary’s narrow de minimis exception is an attributable total of no more than $1, or $5 for a multiyear policy. This does not establish that insurance is optional for §20(a)(5). | S006, §4(d)(2); comments 4(d)-8–10. ecfr.gov+1 |
| R035-P1-C051 | Section 4(d)(3) separately addresses specified voluntary debt-cancellation/suspension coverage. Exclusion requires written optional-status and initial-cost/shorter-term disclosures, the applicable suspension-only and continuing-interest explanations, and an affirmative signed/initialed request after disclosure; unit-cost use is limited as specified. For combined events at one charge, the commentary permits exclusion if at least one covered event is accident or loss of life, health, or income and the required conditions are met. Section 4(d)’s contextual use of “insurance” includes these products unless context indicates otherwise; that does not establish a universal §20(a)(5) exemption for every cancellation/suspension arrangement. | S006, §4(d)(3); comments 4(d)-1 and 4(d)(3)-1–4. ecfr.gov+1 |
| R035-P1-C052 | For §4(d), initial term is the period the insurer/creditor is bound to provide coverage, even if the consumer can cancel or nonpayment can terminate it. A single premium paid or financed in advance generally covers the full credit term. A clearly labeled one-year cost disclosure may replace a longer initial term when that term is indefinite/unclear or periodically charged coverage may be discontinued without obligation. Separate commentary permits certain premium changes without redisclosure solely to preserve finance-charge exclusion. Those rules do not waive §20(a)(5)’s initial-disclosure predicate. | S006, comments 4(d)-2–3 and -11–12. Consumer Financial Protection Bureau |
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C053 | In a refinancing involving precomputed charges, unearned prior finance charge that is neither rebated to the consumer nor credited against the underlying obligation must be included in the new finance charge and reflected in the new APR. Calling it principal or capitalizing it does not remove this treatment. The rule does not itself establish a universal right to a rebate. A cash rebate and a credit to the old obligation must not be assumed to have identical accounting or cash-flow effects. | S001, §20(a), comment 20(a)-4; E004. ecfr.gov+1 |
| R035-P1-C054 | Accrued but unpaid finance charges are included in the amount financed of the new obligation. This is expressly distinguished from the unearned prior charge in C053. The word “capitalized” alone does not reveal which category an amount occupies. | S001, final sentence of comment 20(a)-4. Consumer Financial Protection Bureau |
| R035-P1-C055 | Finance charge is the dollar cost of consumer credit, including charges imposed directly or indirectly as an incident to or condition of credit, subject to stated exclusions. Comparable charges payable in a cash transaction are treated differently. Interest, add-on/discount charges, points, and loan fees are listed examples, subject to applicable exclusions. Payment to a third party or use of a “cost reimbursement” label does not itself settle classification. | S006, §4(a), (b)(1), (3), corresponding general commentary; S012, §1605(a). ecfr.gov+2 |
| R035-P1-C056 | An application fee is excluded under §4(c)(1) when charged to all applicants, whether credit is extended or not. Section 4(c)(2) concerns actual unanticipated late payment, delinquency, default, or similar events. Neither provision supplies a blanket exclusion for a fee charged only on successful refinancing or for any planned deferral/workout charge. Actual terms and practices matter. | S006, §4(c)(1)–(2), corresponding complete comments. ecfr.gov+1 |
| R035-P1-C057 | Section 4(c)(7) excludes specified bona fide, reasonable fees in real-property-secured or residential-mortgage transactions: title/survey-related fees; loan-document preparation; notary/credit-report fees; qualifying preclosing appraisals/inspections; and escrow amounts otherwise outside finance charge. The commentary limits the exclusion to the initial credit decision, addresses allocation of mixed charges, and allows a specified predominantly qualifying closing-service lump sum to include incidental services. Periodic services during the loan term are not brought within the exclusion merely by prepayment. This is a finance-charge rule, not a general allowance in the §20(a)(4) amount-financed base. | S006, §4(c)(7)(i)–(v), comments 4(c)(7)-1–3. ecfr.gov+2 |
| R035-P1-C058 | Section 18(b) determines amount financed by starting with the principal loan amount—or cash price less downpayment for a credit sale—adding financed amounts that are not finance charges and are not already included, and subtracting prepaid finance charges as prescribed. It therefore need not equal the note’s face amount, old payoff amount, or new cash received. | S008, §18(b)(1)–(3), comments 18(b), 18(b)(2)-1; S013, §1638(a)(2). ecfr.gov+2 |
| R035-P1-C059 | A prepaid finance charge is paid separately in cash/check before or at consummation, or withheld from proceeds at any time. Precomputed add-on or discount finance charges are not prepaid merely because they are calculated in advance. Correct treatment depends on the charge and how it enters the transaction. | S004, §2(a)(23), complete corresponding commentary. ecfr.gov+1 |
| R035-P1-C060 | For financed finance charges other than add-on/discount charges, the §18(b)(3) commentary permits a principal starting amount that includes or excludes the charge. If included, the prepaid charge is deducted; if excluded, it must not be deducted again. The choice of presentation does not change its finance-charge character. Add-on/discount charges require their own stated treatment. | S008, comments 18(b)(3)-1.i–iv and -2.i–iii. Consumer Financial Protection Bureau+1 |
| R035-P1-C061 | The amount-financed itemization distinguishes amounts paid directly to the consumer, credited to the consumer’s debt with the creditor, paid to other persons, and prepaid finance charges. Section 18(c) permits the specified written-request alternative to automatically furnishing the separate itemization; if requested, it must be provided. A credit to an existing debt is not automatically cash received. Specialized mortgage alternatives remain held. | S008, §18(c), complete material commentary, particularly 18(c)(1)(i)–(iv). Consumer Financial Protection Bureau+1 |
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C062 | The direct new-disclosure basis is §20(a), amplified by comment 20(a)-1’s requirement for a complete new set. TILA §1638 and the applicable Regulation Z disclosure provisions supply the content and timing. The new disclosure is not limited to the amount of cash newly advanced. | S001, §20(a), comment -1; S013, §1638(a), (b)(1); S007–S008. Consumer Financial Protection Bureau+2 |
| R035-P1-C063 | Section 18 applies to covered closed-end transactions outside §19(e)/(f), with disclosures only as applicable. Its commentary identifies unsecured credit, non-dwelling personal-property credit, certain personal-property dwellings, and reverse mortgages as relevant categories, with different payment-disclosure forms. Ordinary real-property/cooperative-unit transactions route to §19(e)/(f), subject to stated exceptions and the qualifying §3(h) election. This pass identifies that boundary without completing mortgage disclosure requirements. | S008, general comments 18-1 and -3; S005, comment 3(h)-1. Consumer Financial Protection Bureau+1 |
| R035-P1-C064 | Under the ordinary §17(a) route, disclosures must be clear, conspicuous, written, and retainable. Electronic delivery is subject to the incorporated E-SIGN requirements, with specified exceptions. Grouping, segregation, and prominence rules apply; specified creditor, insurance, security-charge, and other items may be separate. The §19(e)/(f)/(g) and private-education qualifications must not be omitted. Full E-SIGN and product-form compliance remain held. | S007, §17(a)(1)–(2). ecfr.gov |
| R035-P1-C065 | The ordinary timing rule is before consummation. Section 17(b) expressly identifies special residential-mortgage, variable-rate, private-education, and mail/telephone or series-of-sales timing, and excludes specified §19 and §20(e) disclosures from its own timing rule. No actual calendar deadline can be derived without the applicable route and consummation facts. | S007, §17(b); S004, §2(a)(13); S013, §1638(b)(1). ecfr.gov+2 |
| R035-P1-C066 | Section 17(g)’s delay to the first payment’s due date requires a purchase order or credit request by mail, telephone, or fax without face-to-face or direct telephone solicitation, and prior written/electronic availability of the listed representative credit information: principal/cash price, total sale price, finance charge, APR and applicable increase circumstances/limits/effect, and repayment terms. It excludes the identified mortgage and private-education disclosures. It is not a general exception for every remote application. | S007, complete §17(g)(1)–(5) and corresponding commentary. ecfr.gov |
| R035-P1-C067 | Section 17(h)’s series-of-sales delay requires an agreement permitting later credit sales to be added to the balance; written consumer approval of APRs, applicable balance ranges, and treatment of unearned charges; and no retained security in an item after receipt of its cash price and attributable finance charge. For that security condition, older purchases are paid first, and same-day purchases are ordered by lowest price first. The delay ends at the current sale’s first-payment due date; the specified mortgage disclosures are excluded. This is not a universal refinance payment-allocation rule. | S007, complete §17(h)(1)–(2). ecfr.gov |
| R035-P1-C068 | Disclosures reflect the legal obligation. Unknown necessary information ordinarily uses the best reasonably available information and must be clearly labeled as an estimate. The rule separately addresses per-diem interest collected at consummation, allowing affected disclosures to use information known when the consummation documents are prepared. These provisions do not authorize invented terms or substitute for an actual agreement. | S007, §17(c)(1)–(2), corresponding legal-obligation and estimate commentary. ecfr.gov+2 |
| R035-P1-C069 | For ordinary early disclosures, §17(f) requires changed terms before consummation unless the stated estimate qualification applies; all changed terms must be redisclosed if APR differs by more than 1/8 percentage point for a regular transaction or 1/4 percentage point for an irregular transaction, subject to the stated mortgage/private-education qualifications. Irregularity concerns multiple advances or irregular payment periods/amounts, excluding merely an irregular first period or first/final payment. A variable-rate feature does not itself make an initially regular amortization schedule irregular. These are disclosure rules, not §20(a)(4) rate-increase permissions. | S007, §17(f)(1)–(2); S019, §22(a)(2)–(3), comments 22(a)(2)-1 and 22(a)(3)-1. ecfr.gov+2 |
| R035-P1-C070 | A later event making an earlier disclosure inaccurate does not itself make that disclosure a violation under §17(e), but new disclosures may nevertheless be required by §17(f), §19, §20, or the identified private-education provision. Earlier accurate disclosures therefore do not establish that a later replacement needs none. | S007, §17(e). ecfr.gov |
| R035-P1-C071 | A complete applicable §18 set includes the creditor, amount financed and relevant itemization, finance charge, APR, applicable variable-rate information, payment schedule/total, and applicable prepayment, late-payment, security, insurance, security-cost, contract-reference, demand, required-deposit, credit-sale, or mortgage-related information. “As applicable” is substantive: total sale price is a credit-sale disclosure, and the late-payment provision distinguishes late charges from deferral/extension charges. Listing a category does not establish that it applies to an unknown transaction. | S008, §18(a)–(r), general comments 18-1–3; S013, §1638(a)(1)–(13). ecfr.gov+3 |
| R035-P1-C072 | Two material qualifications prevent universal numeric-disclosure statements: §18(e) permits omission of APR where finance charge does not exceed $5 when amount financed is $75 or less, or $7.50 when amount financed exceeds $75; §18(h) does not require total-of-payments disclosure for a single-payment transaction. These are legal disclosure thresholds and exceptions, not illustrative loan terms. | S008, §18(e), (h). ecfr.gov+1 |
| R035-P1-C073 | Multiple creditors provide one set and agree who complies. With multiple consumers, ordinary disclosures may be made to any consumer primarily liable; where the transaction is rescindable, disclosures must reach each consumer entitled to rescind. This delivery rule does not resolve who is liable or whether the same-consumer refinancing predicate is met. | S007, §17(d). ecfr.gov |
| R035-P1-C074 | A disclosure classification presupposes the legally established transaction; furnishing a new disclosure is not itself proof of satisfaction, release, novation, lien termination, guarantor discharge, or closure of another credit arrangement. Security disclosure under §18(m) reports the relevant security interest; it does not perform a release. These questions require the contract and applicable law that are absent here. | S001, comment 20(a)-1; S004, §2(a)(25), (b)(3); S008, §18(m), (p). This is a limit on what those provisions establish. Consumer Financial Protection Bureau+2 |
| R035-P1-C075 | The selected classification and disclosure provisions do not themselves require a creditor to offer refinancing, accept an application, approve a concession, make an affordability finding, or promise particular terms. They also do not establish that an unknown transaction is enforceable or beneficial. This conclusion is limited to the selected provisions, not a claim that no other law supplies obligations. | S001, §20(a); S003, §1(b)–(d); S007–S008. ecfr.gov+2 |
| R035-P1-C076 | A lower installment does not establish a lower total cost. The required disclosure structure distinguishes APR, finance charge, payment amount, payment count/timing, and total payments. Without those separate inputs and the applicable fee treatment, a savings conclusion does not follow. This is an inference from the disclosed quantities, not a forecast. | S008, §18(d)–(h); S013, §1638(a). ecfr.gov+2 |
| R035-P1-C077 | An open-end balance transfer is outside the selected closed-end refinancing classification. Repayment of a balance does not, from the open-end definition alone, prove termination of the replenishing plan. Actual conversion to closed-end credit has separate commentary under §17(b); ordinary scheduled repayment under an existing plan cannot simply be relabeled a new §20(a) refinancing. Full open-end transfer, conversion, and card rules remain held. | S004, §2(a)(10), (20), corresponding commentary; S007, comment 17(b)-2. Consumer Financial Protection Bureau+2 |
Reading rule: the general coverage and replacement predicates in C009–C029 remain incorporated. Except for the separately identified variable-rate rule, failing one exception does not by itself finish the legal classification.
| Provision | Cumulative conditions for the stated treatment | Qualification or exception to the exception | Consequence and evidence |
|---|---|---|---|
| §20(a)(1): single-payment renewal | Qualifying single-payment structure; renewal on original terms. Includes periodic interest with final principal. | Permitted accrued-interest capitalization, principal curtailment, and only the incorporated §17(c)(3) factors. Other changed terms/new funds require analysis. No express renewal-count cap or blanket rollover authorization. | If all conditions hold, not treated as refinancing even with replacement. C035–C038; S001/S007; E005. |
| §20(a)(2): APR reduction | Reduced APR plus a corresponding schedule change implementing it. | Shorter maturity, lower installment, or fewer payments can correspond. Longer maturity or increased remaining payment amount/count defeats this exception. A later replacement with an APR increase can require new disclosures even below the first APR. | No inference from “lower payment” alone. C039–C041; S001. |
| §20(a)(3): court agreement | Agreement involving a court proceeding. | The official categories are examples within that predicate. Some judgments/court approvals are separately outside “credit”; third-party financing can still be credit. | A private settlement label is insufficient. C042–C043; S001/S004; E006. |
| §20(a)(4): default/delinquency workout | Schedule or collateral change resulting from default/delinquency; no APR increase; new amount financed does not exceed the precise unpaid-balance/earned-charge/continuation-premium base. | An APR increase or excess amount financed defeats this exception. No general reasonable-cost allowance appears here. Noncash financed charges can matter. | Neither “no cash out” nor “hardship” proves the exception. C044–C047; S001/S006/S009. |
| §20(a)(5): optional-insurance renewal | Renewal, optional insurance bought by the consumer, addition to the existing transaction, and required initial-purchase disclosures previously supplied. | Optional status, renewal status, and initial disclosure compliance cannot be assumed. Separate §4(d) fee-exclusion tests do not establish all these predicates. | A new insurance purchase or unspecified premium capitalization is not automatically within the exception. C048–C052; S001/S006. |
| Comment 20(a)-3: variable-rate treatment | Properly disclosed feature and conforming change avoid refinancing treatment; a comparable index change does not add a feature. | Undisclosed-feature increase or addition of a variable feature independently requires new disclosures even without replacement. Specified principal-dwelling/term cases also invoke §19(b). | This commentary qualification must be checked alongside the general replacement test. C030–C034; S001/S004/S017; E002–E003. |
These are source examples, not invented transactions or findings about an account.
| Example ID | Complete material proposition illustrated | Conditions preserved; evidentiary limit |
|---|---|---|
| E001 | Comment 20(a)-1 contrasts deferral of individual installments with cancellation/substitution and explains that even substantially unchanged replacement terms can trigger disclosures. | Contract and applicable law determine whether complete replacement occurred. C024–C026; S001. |
| E002 | Comment 20(a)-3.i uses a renewable balloon-payment mortgage whose variable feature had previously been properly disclosed. | Only a change conforming to that disclosed feature receives the stated treatment. No blanket mortgage-renewal or maturity-extension result. C030; S001. |
| E003 | Comment 20(a)-3.ii.B uses the corresponding Board-selected replacement for each specified LIBOR tenor. | Correct tenor and defined replacement matter. Other replacements use the qualified comparability analysis. No actual index or rate was calculated. C032–C033; S001/S004/S017. |
| E004 | Comment 20(a)-4 describes an add-on-charge transaction replaced with new money, without refund or credit of the old unearned charge. | The old unearned charge enters the new finance charge and APR; accrued unpaid charges receive different treatment. No refund entitlement or amount is inferred. C053–C054; S001. |
| E005 | Comment 20(a)(1)-1 expressly allows the stated accrued-interest addition, minor-factor changes, and principal curtailment within the renewal analysis. | The underlying qualifying single-payment/original-terms requirement remains. C035–C037; S001/S007. |
| E006 | Comment 20(a)(3)-1 gives reaffirmation, settlement, and post-judgment examples. | Court involvement remains necessary; the separate credit-definition issue remains. No case, filing, or actual agreement was examined. C042–C043; S001/S004. |
All six derive from the complete current §20(a) commentary. Historical rates, amounts, or product structures appearing in other official calculation examples are not adopted as current offers, assumptions, or outcomes. Consumer Financial Protection Bureau
Status convention: “Partial” means the generic federal rule is answered, while its application is unresolved because the necessary facts are parent-held. “Excluded” means the fuller framework is expressly outside this pass. Every branch incorporates the complete conditions in its cited claims.
The final column authorizes only a generic public-law inquiry. It is not an instruction to obtain or search for actual parties, records, contracts, accounts, or identifiers.
| Branch / status | Conditional supported rule and evidence | Missing evidence | Adverse inference to avoid | Next permissible public-law inquiry |
|---|---|---|---|---|
| B001 — Partial: coverage/purpose unknown | Apply consumer-purpose, creditor, closed-end, and exemption predicates before §20(a). C009–C022; S003–S005/S010–S014. | Purpose, actor status, structure, exemption facts. | A personal-sounding label proves consumer coverage. | Examine the relevant generic §2 definition and §3 exemption/comment once the legal category is identified. |
| B002 — Partial: original creditor/holder/servicer/successor unknown | Section 20(a) expressly includes original creditor, holder, or servicer; “successor” alone does not resolve the role. C014, C028; S001/S004/S009. | Legal role and succession basis. | Every new brand is a new creditor, or every successor is automatically the original creditor for all provisions. | Compare comment 20(a)-5 with the distinct comment 23(f)-4 only for their respective purposes. |
| B003 — Partial: same consumer unknown | The general test requires the same consumer; confirmed-successor provisions do not automatically answer it. C011, C024, C073; S001/S004/S007. | Obligors, legal capacity, any assumption/substitution. | Ownership transfer, a guaranty, or receipt of notices establishes the same-consumer predicate. | Review §2(a)(11) and comment 20(a)-1; preserve §20(b) as a separate held route. |
| B004 — Partial: satisfaction/replacement unknown | Complete legal replacement is essential to the general test. C024–C026; S001/S004. | Contractual effect and applicable law. | A new schedule, statement, signature page, or document title necessarily extinguishes the old obligation. | Revisit comment 20(a)-1’s legal test; governing-law research remains parent-held. |
| B005 — Partial: label differs from substance | Consolidation, modification, renewal, rewrite, novation, or refinancing terminology is not dispositive. C025–C027; S001. | Legal substance of the change. | The heading on a document controls federal classification. | Compare the generic legal effects with §20(a) and each applicable exception. |
| B006 — Partial: new lender | A person outside original-creditor/holder/servicer coverage undertakes a new transaction under Regulation Z rather than a §20(a) refinancing. C029, C062–C065; S001/S007/S008/S013. | New actor’s creditor status, coverage, consummation, applicable route. | Outside §20(a) means no new disclosures or automatic old-debt release. | Apply §§1–3, then the appropriate new closed-end disclosure provisions. |
| B007 — Partial: single-payment renewal | The exception covers specified single-payment structures renewed on original terms, with only the stated allowances. C035–C037; S001/S007; E005. | Original payment structure and renewal terms. | Any balloon extension or installment-loan extension is exempt. | Read §20(a)(1), its complete comment, and §17(c)(3) together. |
| B008 — Partial: changed original terms | Changes beyond the express renewal allowances require renewed analysis; other exceptions/general predicates still matter. C027, C035–C037; S001/S007. | Nature of changed rate, fees, maturity, principal, or payment structure. | Any change automatically is refinancing, or any unchanged nominal rate preserves renewal status. | Identify which exact exception, if any, addresses that type of change. |
| B009 — Partial: successive renewals/variable feature | No express §20(a) renewal-count cap was found; each event remains subject to its conditions and the variable-rate rules. C030–C038; S001/S004/S017. | Prior disclosure and renewal terms; feature/index changes. | No written count limit means an entitlement to unlimited renewals. | Examine comments 20(a)-3 and 20(a)(1)-1; use the public index-definition cross-reference only if necessary. |
| B010 — Partial: lower APR/payment schedule | Reduced APR requires a corresponding schedule change; longer maturity or increased remaining amount/count defeats this exception. C039–C041; S001. | Old remaining schedule and revised APR/schedule. | A smaller installment proves exemption or savings. | Apply comment 20(a)(2)-2’s remaining-obligation comparison. |
| B011 — Partial: court proceeding | Court involvement is required; credit-definition exclusions may independently matter. C042–C043; S001/S004; E006. | Legal nature of the agreement and proceeding connection. | All settlements, reaffirmations, or collection compromises receive the same classification. | Review §20(a)(3) and comment 2(a)(14)-1.ii generically; no case search. |
| B012 — Partial: default/delinquency | The schedule/collateral change must result from default or delinquency, with both rate and amount conditions satisfied. C044–C046; S001. | Status, causal basis, rate and financed components. | Hardship, anticipated difficulty, or a request proves default and exception eligibility. | Revisit the full text of §20(a)(4), without inventing a delinquency clock. |
| B013 — Partial: rate increase | APR increase defeats the workout exception; later increased APR through replacement also defeats reliance on the reduction exception as stated. C041, C045; S001. | Correct old/new APR and charge treatment. | An unchanged nominal interest rate proves unchanged APR; §22 tolerance permits an increase. | Use §§4, 18, and the narrowly relevant §22 rules to distinguish charge classification from rate permission. |
| B014 — Partial: new advance | Section 20(a)(4) compares new amount financed with the specified base; no-cash-out is insufficient. C046, C054, C058–C061; S001/S004/S008. | All financed components and any existing amounts accrued. | Only cash delivered is additional credit. | Apply the §18(b) amount-financed method and then the separate §20(a)(4) comparison. |
| B015 — Partial: claimed reasonable costs | No general reasonable-cost addition appears in §20(a)(4). The §4(c)(7) and §23(f)(2) tests serve different purposes. C047, C057; S001/S006/S009. | Cost type, legal authorization, finance-charge status, purpose. | “Reasonable” or “bona fide” automatically preserves the workout exception. | Read the applicable fee provision and keep the separate rescission calculation bounded. |
| B016 — Partial: optional-insurance renewal | Renewal, optional purchase, addition to the existing transaction, and compliant initial disclosures must all be established. C048–C052; S001/S006. | Optional status, initial disclosures, renewal versus new coverage, type/term. | Any premium financing or §4(d) exclusion proves §20(a)(5). | Compare §20(a)(5) with the applicable complete §4(d) provision/comment. |
| B017 — Partial: old unearned finance charge | Unrebated/uncredited unearned prior charge enters the new finance charge/APR. C053; S001; E004. | Earned/unearned decomposition and actual rebate/credit treatment. | Capitalization converts all prior charges into new amount financed. | Apply comment 20(a)-4 before the §18(b) calculation. |
| B018 — Partial: capitalized arrears versus cash | Accrued unpaid finance charges enter new amount financed; other fees and unearned amounts require separate classification. C054–C061; S001/S004/S006/S008. | Principal, earned interest, unearned charge, fees, financed costs, disbursement categories. | “Arrears,” “principal,” or “capitalized” is a complete regulatory classification. | Use §4, §2(a)(23), and §18(b)/(c) by component. |
| B019 — Partial: added/released collateral | Collateral change can fit §20(a)(4) only with its default/delinquency and financial conditions; threshold and rescission consequences are separate. C020, C044–C047, C074; S001/S005/S009. | Existing/new security and legal effect. | Added collateral always is refinancing, or revised disclosures release an existing lien. | Compare comments 3(b)-6.ii and 20(a)-1 with §20(a)(4); retain full rescission/lien law as held. |
| B020 — Partial: open-end transfer or still-open arrangement | Closed-end status depends on the plan definition; payoff does not establish closure. Full balance-transfer treatment lies elsewhere. C013, C077; S004/S007. | Plan terms, replenishment, whether a new closed-end agreement exists. | A transferred or zero balance proves a closed account or §20(a) refinancing. | Review §2(a)(20) and identify the separate Subpart B or conversion route without applying it here. |
| B021 — Excluded: mortgage/assumption/rescission framework | Section 20(a) classification does not resolve §20(b) assumption, mortgage form/timing, ARM notices, or rescission. C034, C047, C063–C065, C074; S001/S007–S009. | Product, security, consumer identity, timing, and transaction type. | New disclosures establish an assumption, rescission right, waiver, or lien discharge. | If the parent hold is released, investigate the specific §19, §20(b)–(e), §23, or mortgage-subpart branch separately. |
| B022 — Partial: lower installment/longer term/total cost | Lower payment alone is not savings; longer maturity also defeats the APR-reduction exception. C040, C076; S001/S008/S013. | Entire schedule, term, charges, rate treatment, final payment. | Lower monthly burden necessarily lowers finance charge or total payments. | Examine only the applicable disclosure quantities; no amortization forecast without complete assumptions. |
| B023 — Partial: contractual release unknown | Classification does not adjudicate obligor, guarantor, lien, or account release. C024–C026, C074; S001/S004/S008. | Governing law and legal effect of the instruments. | A federal “refinancing” label itself releases every old obligation or security. | Preserve the federal classification; any jurisdiction-specific release inquiry remains held. |
| B024 — Partial: old exemption/new coverage | A replacement must qualify for its own threshold exemption; former business credit has its own consumer-purpose replacement rule. C017, C019–C022; S005/S011/S018. | Relevant period, purpose, extension/commitment amount, security, other exemptions. | The original exemption automatically follows every replacement. | Apply comment 3(b)-5.ii or 3(a)-6, as appropriate, using the legally relevant period. |
| B025 — Partial: consummation/disclosure timing | Ordinary timing is before legally determined consummation; only specific routes permit different timing. C023, C063–C070; S004/S007/S019. | Contractual obligation point, delivery route, estimates, later changes. | Application, approval, funding, signature, or first payment universally supplies the deadline. | Review §2(a)(13), §17(b), and only the applicable timing exception. |
| B026 — Partial: new agreement/other-law overlays | A complete new applicable disclosure set does not determine enforceability, authorization of charges, qualification, affordability, or compliance with every other product law. C062–C075; S001/S007/S008/S013. | All contractual and product-specific facts. | Disclosure compliance equals valid terms, approval, or a consumer right to refinancing. | Identify the exact separate public-law framework, retaining the parent holds until separately authorized. |
| B027 — Unresolved interval: version/effective period | Current bodies and the identified final issuances support the stated rules through their recorded cutoffs. They do not exhaustively clear the remaining interval or establish a future threshold. C001–C008; S001/S010–S018. | Official material after compilation cutoffs; any relevant future-effective issuance. | A crawl date, current banner, negative search, or old final rule proves unchanged law through all later dates. | Reopen the official current body and relevant final-publication material for the exact unresolved interval. |
The entry columns below are intentionally blank. No person, party, account, transaction, property, amount, date, or outcome has been inserted.
| Audit field | Evidence / analysis | Authority / read note |
|---|---|---|
| Scope of proposed legal inquiry | ||
| Applicable regulatory instrument and version | ||
| Official source access date and time zone | ||
| Compilation cutoff and unresolved interval | ||
| Relevant effective or transition provision | ||
| Consumer-credit purpose classification | ||
| Natural-person / organizational / trust treatment | ||
| Creditor-definition predicates | ||
| Regular-extension measuring period and basis | ||
| Applicable actor exclusion or alternative regulatory route | ||
| Closed-end / open-end classification | ||
| Applicable exemption and measuring period | ||
| Existing obligation’s Subpart C coverage | ||
| Original-creditor / holder / servicer role | ||
| Successor-role legal basis | ||
| Same-consumer predicate | ||
| Governing-law question | ||
| Satisfaction or extinguishment predicate | ||
| Complete replacement predicate | ||
| Label and substantive legal effect | ||
| Existing obligation remaining open | ||
| New-creditor transaction boundary | ||
| Single-payment structure | ||
| Original terms and proposed changes | ||
| Renewal sequence and relevant prior disclosures | ||
| Variable-rate feature and index treatment | ||
| APR-reduction exception predicates | ||
| Remaining payment schedule comparison | ||
| Court-proceeding connection | ||
| Default or delinquency predicate and causal connection | ||
| Existing and revised APR classification | ||
| Unpaid-balance components | ||
| Earned unpaid finance charge | ||
| Unearned prior finance charge | ||
| Rebate treatment | ||
| Credit against prior obligation | ||
| New cash and payments on consumer’s behalf | ||
| Financed non-finance-charge costs | ||
| New finance charges | ||
| Prepaid finance charges | ||
| Amount-financed calculation method | ||
| Duplicate-inclusion or duplicate-subtraction check | ||
| Workout amount-financed comparison | ||
| Insurance type, optional status, and renewal status | ||
| Initial insurance disclosures and affirmative request | ||
| Continuation-premium treatment | ||
| Existing and revised security requirements | ||
| Separate lien / obligor / guarantor release question | ||
| Applicable disclosure-content route | ||
| Consummation predicate | ||
| Delivery, retainability, and electronic-form conditions | ||
| Disclosure timing and exception predicates | ||
| Estimate and early-change treatment | ||
| Applicable disclosure recipients | ||
| Separate product-specific framework | ||
| Missing evidence and adverse inference to avoid | ||
| Next permissible generic public-law inquiry | ||
| Remaining parent holds | ||
| Researcher self-check | ||
| Independent review status |
No transaction illustration or amortization model is supplied.
The verified §18(b) method is stated in C058–C060, and the specific prior-charge rules are stated in C053–C054. A further symbolic reconciliation would still require decisions about:
Those missing classifications cannot be repaired by an arithmetic identity. In particular, subtracting the same financed charge twice would be inconsistent with the commentary’s alternative presentation methods, and treating all carried-forward charges as new principal would lose the earned/unearned distinction. C053–C060; S001/S004/S008. Consumer Financial Protection Bureau+3
No actual or invented amount, rate, payment schedule, payoff date, savings result, tax effect, or credit effect is calculated.
“Answered” below means answered at the requested generic public-law level. It does not mean an actual transaction has been classified.
| Requested question / material subquestion | Status | Findings, claims, sources, examples, branches | Missing evidence or held limit | Exact permissible next inquiry |
|---|---|---|---|---|
| 1 — Complete current §20(a) | Answered, with temporal limit | C001, C024–C048; S001; comparison table | Post-October-26 compilation interval not exhaustively cleared | Official current body and final publications for that interval |
| 1 — Complete general and exception commentary | Answered | C025–C054; S001; E001–E006 | Full other §20 commentary not claimed | None needed for the selected text; use another subsection only if separately relevant |
| 1 — Old covered obligation; satisfaction; replacement; same consumer | Answered generically / application unresolved | C024–C027; B003–B004 | All contractual and identity predicates held | Comment 20(a)-1 and §2 definitions; governing-law question remains held |
| 1 — Original creditor, holder, servicer, successor | Answered generically / application unresolved | C014, C028–C029; B002, B006 | Role and succession facts absent | Compare the specific coverage language; do not import §23’s role definition |
| 1 — Labels versus legal effect | Answered | C025–C027; E001; B005, B008 | Actual legal effect absent | The precise federal test and, only if authorized later, relevant general contract law |
| 1 — Different creditor/new transaction | Answered | C029, C062–C065; B006 | New actor/coverage/disclosure route unknown | §§1–3 and applicable new-transaction provisions |
| 1 — No automatic obligor/lien release or savings | Answered as a limit | C074–C076; B022–B023 | Contract, security, cost facts absent | Separate generic release or cost framework only after parent hold |
| 2 — Consumer credit and purpose definitions | Answered | C009–C012, C016–C017; S003–S005/S010; B001 | Purpose facts held | Applicable §2/§3 purpose provision |
| 2 — Closed-end/open-end boundary | Answered | C013, C077; B020 | Plan facts held | §2(a)(20); separate transfer/conversion framework held |
| 2 — Creditor definition and regularity | Answered | C014–C015; S004/S010 | No actual actor classification; illustration-table rendering gap | Operative §2(a)(17), not an actor search |
| 2 — Actor exclusion | Answered as a boundary | C018; S003/S014/S018 | Alternative Part 226 framework not completed | General Board/CFPB allocation if relevant and separately authorized |
| 2 — Exemption framework and measuring base | Answered | C019–C022; S005/S011/S018; B024 | Product/security/period facts held; future threshold unverified | Exact §3 exemption and applicable annual rule |
| 2 — Consummation and contract/state-law dependence | Answered generically / application unresolved | C023; B004, B025 | Governing law and binding event absent | §2(a)(13) commentary; state-law inquiry held |
| 2 — New-disclosure legal basis and extent | Answered | C062–C073; S001/S007/S008/S013/S019 | Actual applicable route unknown | §18 or the identified specialized route |
| 2 — Old unearned finance charge | Answered | C053–C054; E004; B017–B018 | Earned/unearned and rebate/credit facts absent | Comment 20(a)-4 and §18(b) |
| 2 — No offer/approval/affordability entitlement | Answered as a limit | C075; B026 | Full substantive product laws held | Only a separately authorized applicable framework |
| 3 — Single-payment renewal | Answered | C035–C038; E005; B007–B009 | Original and renewal terms absent | §20(a)(1), comment -1, §17(c)(3) |
| 3 — APR reduction and schedule limits | Answered | C039–C041; B010, B013 | Remaining/revised schedules absent | Comments 20(a)(2)-1–2 |
| 3 — Court agreement | Answered | C042–C043; E006; B011 | Proceeding connection held; no case inquiry | §20(a)(3), comment 2(a)(14)-1.ii |
| 3 — Default/delinquency schedule or collateral change | Answered | C044–C047; B012–B015, B019 | Status, causation, APR, and amount components absent | Full §20(a)(4), not a generic hardship rule |
| 3 — Optional-insurance renewal | Answered | C048–C052; B016 | Optional status, renewal, initial disclosures absent | §20(a)(5) and relevant complete §4(d) branch |
| 3 — Rate-increase and additional-credit triggers | Answered | C041, C045–C046; B013–B014 | Correct APR and amount-financed inputs absent | §§4, 18, and §20(a)(4) comparison |
| 3 — Reasonable costs | Answered, narrowly bounded | C047, C057; S006/S009; B015 | No actual fee legality or rescission result | Keep §4(c)(7), §20(a)(4), and §23(f)(2) separate |
| 3 — Successive renewals and variable-rate considerations | Answered | C030–C038; E002–E003; B009 | Feature disclosures/index/renewal terms absent | Comment 20(a)-3; Part 253 only if separately necessary |
| 3 — Complete material official §20(a) examples | Answered | E001–E006, tied to C024–C054 | No actual application; unrelated historical numeric examples not adopted | None needed for the selected illustrations |
| 4 — Necessary timing provisions | Answered | C023, C065–C070; S007/S019; B025 | Actual route/consummation unknown | Exact §17 timing branch |
| 4 — Necessary disclosure-content provisions | Answered | C061–C064, C071–C073; S008/S013 | Product-specific applicability unknown | Applicable §18 categories; mortgage route held |
| 4 — Finance-charge/amount-financed distinction | Answered | C053–C061; S001/S004/S006/S008/S012/S013 | Component facts absent | Charge-by-charge public-law classification |
| 4 — Paid off versus still open | Answered as a distinction / application unresolved | C024–C029, C074, C077; B004, B020, B023 | Legal closure/replacement facts absent | General replacement and plan definitions |
| 4 — Existing debt/new money; principal/charges; arrears/cash | Answered | C046, C053–C061; B014, B017–B018 | Component allocation unknown | Comment 20(a)-4 and §18(b)/(c) |
| 4 — Changed/unchanged security and release | Answered as a distinction / application unresolved | C020, C044–C047, C074; B019, B023 | Security and contract facts absent | Separate coverage, disclosure, and release inquiries |
| 4 — Open-end transfers/cards/promotions | Excluded beyond boundary | C013, C077; B020 | Parent hold | Subparts B/G only in a separate authorized investigation |
| 4 — Assumptions/ARM/mortgage/rescission | Excluded beyond necessary cross-references | C034, C047, C063–C065; B021 | Parent hold; only §23(f)(2) comparison completed | Specific §19/§20(b)–(e)/§23 branch |
| 4 — High-cost/higher-priced loans; private education | Excluded beyond coverage pointers | C015, C019, C021, C063–C065 | Full §§32, 35, 46–48 frameworks held | Relevant product framework separately |
| 5 — Provision-specific comparison | Answered | Section 3; C027, C035–C052 | Actual applicability held | None required to complete the generic comparison |
| 5 — At least sixteen substantive branches | Answered | B001–B027, each with rule, evidence, missing facts, inference limit, next inquiry | Individual application unresolved/excluded as marked | Exact branch-specific public-law inquiry |
| 5 — Entirely blank worksheet | Answered | Section 5 | All entry fields deliberately blank | No factual entry or record query authorized |
| 6 — Optional symbolic reconciliation | Not supplied, with reason | Section 6; C053–C061 | Necessary component classifications absent | Resolve generic charge categories before any separately authorized model |
| 6 — Arithmetic versus regulatory classification | Answered | C053–C061; Section 6 | Arithmetic cannot establish legal character or authorization | Applicable finance-charge rule first |
| 6 — No unsupported amortization/savings forecast | Answered by exclusion | C076; B022; Section 6 | Timing, rate, term, fees, final payment, rounding absent | No forecast within this pass |
| Source method — versions, dates, read bounds, failures | Answered, with explicit gaps | Source register; C001–C008; Section 8 | Compilation intervals and listed access limits | Narrow official-source follow-up only |
| Review/acceptance boundary | Answered as a limit | Section 9 | No independent reviewer or acceptance action | Separate owner-controlled review |
| Log item | What was actually done | Result and consequence |
|---|---|---|
| L001 — Core rule | Opened current eCFR §20 and CFPB §20/commentary presentations. | Complete §20(a) and all its current commentary read. Other §20 frameworks were not represented as complete. |
| L002 — Definitions and exemptions | Opened the current §§1–3 bodies and material official commentary, then statutory definitions/exemptions. | Coverage gates and their conditional nature established; no actual entity or transaction classified. |
| L003 — Charges and disclosures | Read the selected complete material portions of §§4, 17, 18 and their interpretations. | Established the earned/unearned distinction, amount-financed method, and ordinary disclosure route with material exceptions. |
| L004 — Reasonable-cost distinction | Read §23(f)(2) and complete comment 23(f)-4. | Confined that calculation and successor rule to the rescission comparison; no full rescission conclusion. |
| L005 — Status and amendments | Read the identified 2011, 2021, 2022-correction, 2023, and 2026-threshold issuing materials. | Historical and operative provisions distinguished. Search results alone were not treated as authority. |
| L006 — PDF read limits | Read selected parsed text in S017 and S018 at the printed pages/indices recorded above. | No claim of whole-PDF visual reading, scanned-page inspection, form verification, or pixel review. |
| L007 — §22 recovery | A first retrieval was truncated; reopened the body and corresponding commentary. | Relevant §22(a)(1)–(3) and comments were then readable. No unresolved retrieval gap remains for C069’s narrow use. |
| L008 — Currentness checks | Examined current compilation notices, agency current-version bodies, and necessary final-publication materials. | Supports the recorded text and dates; does not establish exhaustive clearance after each compilation cutoff. |
| Failure / limit | Complete URL or exact location | Treatment |
|---|---|---|
| F001 — Full eCFR Supplement I too large | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Supplement%20I%20to%20Part%201026 | Retrieval failed with a content-size error. The necessary commentary was read from section-specific CFPB presentations and relevant Federal Register material. This is an access failure, not evidence of absence. |
| F002 — Federal Reserve commentary mirror too large | https://www.federalreserve.gov/frrs/regulations/consumer-financial-protection-bureaus-official-staff-commentary-on-regulation-z.htm | Content-size error. No search snippet from this mirror supports a substantive claim or status conclusion. |
| F003 — Legacy OLRC granule links failed | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1602&num=0&edition=prelim https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1603 | Failed legacy retrievals. Recovered using the official /us/usc/119-121/ sources in S010–S013. |
| F004 — OLRC title-query links inaccessible | https://uscode.house.gov/view.xhtml?req=title:15%20section:1602%20edition:prelim https://uscode.house.gov/view.xhtml?req=title:15%20section:1603%20edition:prelim https://uscode.house.gov/view.xhtml?req=title:15%20section:1638%20edition:prelim | Not used as evidence. The successful statutory snapshots and their actual currency notices control the register. |
| F005 — Batched output truncation | Selected definition/disclosure retrievals; initial §22 retrieval | Reopened the material portions individually. A truncated response was not counted as a complete read. |
| F006 — CFPB §3 parsing omission | S005, §3(h)(6) and following material | Recovered complete text from eCFR, including the disclosure election and paragraph (i). |
| F007 — Creditor illustration table not rendered | S004, numerical example table within creditor commentary | Not reconstructed or relied on. The operative numerical standards and readable counting commentary support C015. |
| F008 — Future threshold not verified | Official annual-threshold search and S018 | No 2027 threshold authority is certified. Lack of a retrieved future rule is not proof that none exists. |
| F009 — Incorporated frameworks not fully read | Part 253; Appendix J; E-SIGN; full §§19, 20(b)–(e), 23, 32, 35, 46–48; Board Part 226 | Specific held boundaries, not silent assumptions. The report states only the narrow cross-reference or distinction actually supported. |
No CFPB circular, bulletin, or advisory opinion supplies an operative premise here. Consequently, this report does not rely on a guidance item whose status would need to be established through the withdrawn-guidance register.
| Check | Result |
|---|---|
| Independent R035 foundation | Fresh R035 primary-source browsing used; R033 findings were not adopted. |
| Complete selected core | Entire §1026.20(a), every nested exception, all general comments, and every exception comment read. |
| Material exceptions preserved | Single-payment allowances, APR/schedule restrictions, court predicate, default/delinquency causation, APR and amount-financed limits, insurance renewal/initial disclosures, and variable-rate qualifications retained. |
| Different-creditor distinction | Original creditor/holder/servicer coverage separated from a new transaction by another person. |
| Prior-charge treatment | Unearned unrebated/uncredited charges separated from accrued unpaid charges; no automatic refund right inferred. |
| “Reasonable costs” distinction | Finance-charge exclusion, workout amount-financed test, and rescission calculation kept separate. |
| Quantitative claims | Limited to sourced legal thresholds, periods, counts, and tolerances, with their measuring bases and triggers; no fabricated transaction values. |
| Examples | Only material official generic §20(a) illustrations used; no actual or fictional account record created. |
| Worksheet | Evidence and authority entry fields remain blank. |
| Read limits | Selected versus whole reads, HTML versus parsed PDF, and inaccessible content expressly identified. |
| Source independence | Formats and sections of Regulation Z grouped as one instrument family, not independent corroboration. |
| Review status | This is the researcher’s self-check. No independent review, component acceptance, parent acceptance, operational acceptance, or publication acceptance is claimed. |
| Scope completion | The focused public-law investigation is delivered with its stated unresolved intervals and parent holds. It does not finish A035. |
END R035 PASS-01.
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Source ID · Issuer; exact instrument or section · Complete literal HTTPS URLs · 10 data rows
| Source ID | Issuer; exact instrument or section | Complete literal HTTPS URLs | Version, actual read extent, and limits |
|---|---|---|---|
| R035-P1-S001 | CFPB, 12 CFR 1026.20, Disclosure requirements regarding post-consummation events; Supplement I, 20(a) Refinancings | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.20 https://www.consumerfinance.gov/rules-policy/regulations/1026/20/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-20/ | Complete §20(a), including (1)–(5), and complete corresponding commentary: general comments 1–5; 20(a)(1)-1; 20(a)(2)-1 and -2; 20(a)(3)-1; 20(a)(4)-1; 20(a)(5)-1. eCFR through October 26, 2026; CFPB labels its presentation current. Other §20 frameworks were not fully investigated. Relevant issuance history is separately recorded in S015–S017. |
| R035-P1-S002 | CFPB, Supplement I to Part 1026—Official Interpretations, Introduction | https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-0/ | Complete substantive introductory comments I-1–I-4 read. Used to identify the official interpretation vehicle and treatment of examples. Full enforcement, defenses, and remedies remain held. |
| R035-P1-S003 | CFPB, §1026.1, Authority, purpose, coverage, organization, enforcement, and liability, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.1 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-1/ | Body (a)–(d), complete relevant coverage commentary under 1(c), and selected organizational/effective-date commentary read. Relied on for general coverage and subpart boundaries, not a complete liability or territorial-law analysis. Current compilation through October 26, 2026. |
| R035-P1-S004 | CFPB, §1026.2, Definitions and rules of construction, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.2 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-2/ | Selected complete definitions: (a)(10)–(14), (17), (20), (22)–(25), (28), and relevant paragraph (b) construction rules. Corresponding material consumer, credit, consummation, creditor, open-end, and prepaid-finance-charge commentary read. The numerical illustration table within creditor commentary did not render; it is not relied on. The operative creditor thresholds and explanatory counting text were read. Part 253, incorporated by (a)(28), was not separately investigated. |
| R035-P1-S005 | CFPB, §1026.3, Exempt transactions, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.3 https://www.consumerfinance.gov/rules-policy/regulations/1026/3/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-3/ | Complete body (a)–(i) read. Material commentary read: 3(a)-1–10; 3(b)-1–3 and -5–7; public-utility, securities-account, home-fuel, student-loan, and 3(h) partial-exemption commentary. Historical/open-end transition material was distinguished from this closed-end investigation. A CFPB parsing omission in (h)(6) was recovered from eCFR. |
| R035-P1-S006 | CFPB, §1026.4, Finance charge, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-A/section-1026.4 https://www.consumerfinance.gov/rules-policy/regulations/1026/4/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-4/ | Material provisions read: (a); relevant examples in (b); (c)(1), (2), and (7); complete (d)(1)–(4); and (e). Complete 4(d) commentary, including initial-term, unit-cost, single-interest, debt-cancellation/suspension, and telephone-purchase qualifications, read. Relevant 4(a), 4(c)(1), 4(c)(2), 4(c)(7), and 4(e) commentary read. This is not a complete fee/product dossier. |
| R035-P1-S007 | CFPB, §1026.17, General disclosure requirements, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.17 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-17/ | Complete operative body (a)–(h) read; historical student-transition paragraph (i) distinguished. Material commentary on timing, legal obligation, estimates, minor irregularities, multiple parties, subsequent/early changes, mail or telephone requests, and series of sales read. Selected renewable-balloon commentary was read without completing the mortgage framework. |
| R035-P1-S008 | CFPB, §1026.18, Content of disclosures, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.18 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-18/ | Body (a)–(r) and relevant routing language concerning mortgage disclosures read. Complete material general, amount-financed, prepaid-charge, and itemization commentary read; selected remaining commentary used only for identified disclosure categories. Full mortgage payment-summary provisions and mortgage forms remain held. |
| R035-P1-S009 | CFPB, §1026.23, Right of rescission, narrowly selected cross-reference | https://www.consumerfinance.gov/rules-policy/regulations/1026/23/ https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-23/ | Complete §23(f)(2) and complete comment 23(f)-4 read to distinguish its refinancing-cost calculation and original-creditor/successor rule from §20(a). No complete rescission investigation or rescission eligibility determination. |
| R035-P1-S019 | CFPB, §1026.22, Determination of annual percentage rate, and corresponding commentary | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/subpart-C/section-1026.22 https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-22/ | Complete (a)(1)–(3) and corresponding material comments read, including the irregular-transaction definition and qualification for initially regular variable-rate schedules. Used only to support §17(f)’s early-disclosure boundary. Appendix J, computation tables, and full mortgage tolerances were not investigated. |
Source ID · Issuer; title · Complete literal HTTPS URL · 5 data rows
| Source ID | Issuer; title | Complete literal HTTPS URL | Actual read bounds and limits |
|---|---|---|---|
| R035-P1-S010 | Congress; OLRC publication, 15 USC 1602—Definitions and rules of construction | https://uscode.house.gov/us/usc/119-121/t15/s1602/ | Relevant definitions in (a)–(j), particularly credit, creditor, consumer purpose, and open-end credit. Specialized mortgage/private-education definitions elsewhere in the section are not treated as completed product frameworks. |
| R035-P1-S011 | Congress; OLRC publication, 15 USC 1603—Exempted transactions | https://uscode.house.gov/us/usc/119-121/t15/s1603/ | Complete numbered operative exemptions (1)–(7) and displayed relevant amendment/indexation notes read. The statutory base amount is distinguished from the adjusted 2026 regulatory threshold. |
| R035-P1-S012 | Congress; OLRC publication, 15 USC 1605—Determination of finance charge | https://uscode.house.gov/us/usc/119-121/t15/s1605/ | Operative body and displayed notes read; reliance limited to general finance-charge, insurance, property-insurance, and specified security-charge provisions. Full mortgage tolerance/remedy analysis excluded. |
| R035-P1-S013 | Congress; OLRC publication, 15 USC 1638—Transactions other than under an open end credit plan | https://uscode.house.gov/us/usc/119-121/t15/s1638/ | Paragraph (a), including the applicable disclosure categories, and (b)(1) read. Reliance principally on (a)(1)–(13) and the general before-extension disclosure requirement. Later specialized mortgage provisions were not fully investigated. |
| R035-P1-S014 | Congress; OLRC publication, 12 USC 5519—Exclusion for auto dealers | https://uscode.house.gov/us/usc/119-121/t12/s5519/ | Complete (a)–(f) and displayed effective-date note read for the actor boundary incorporated by §1026.1(c). No dealer, licensing, business, or entity lookup; no full investigation of Board Regulation Z, Part 226. |
Source ID · Issuer; exact title and publication · Complete literal HTTPS URLs · 4 data rows
| Source ID | Issuer; exact title and publication | Complete literal HTTPS URLs | Status, dates, exact read extent, and page/index limits |
|---|---|---|---|
| R035-P1-S015 | CFPB, Truth in Lending (Regulation Z), 76 FR 79768 | https://www.federalregister.gov/documents/2011/12/22/2011-31715/truth-in-lending-regulation-z | Historical interim final recodification; published December 22, 2011, effective December 30, 2011. Read header, summary, dates, transfer/recodification explanation, and historical complete §20(a) commentary. Rule text begins at printed p. 79772; relevant historical commentary at p. 79992. HTML read; no PDF-index claim. This historical issuance does not establish that the commentary remained unchanged. |
| R035-P1-S016 | CFPB, Facilitating the LIBOR Transition (Regulation Z), 86 FR 69716; associated Correction, 87 FR 8733 | https://www.federalregister.gov/documents/2021/12/08/2021-25825/facilitating-the-libor-transition-regulation-z https://www.federalregister.gov/documents/2022/02/16/2022-03344/facilitating-the-libor-transition-regulation-z-correction https://www.consumerfinance.gov/rules-policy/final-rules/facilitating-libor-transition-regulation-z/ | Final rule published December 8, 2021; general effective/compliance date April 1, 2022. Read dates, material closed-end explanation, and complete amended §20(a) commentary, printed p. 69792. Other open-end/appendix transition dates were distinguished. Correction published/effective February 16, 2022; complete correction read: two preamble hyperlinks, not a substantive §20(a) amendment. HTML only. Later §20(a) changes are in S017. |
| R035-P1-S017 | CFPB, Facilitating the LIBOR Transition Consistent With the LIBOR Act (Regulation Z), 88 FR 30598 | https://www.govinfo.gov/content/pkg/FR-2023-05-11/pdf/2023-09129.pdf | Interim final rule with request for comments; published May 11, 2023, effective May 15, 2023. It is an effective issuance, not merely a proposal. Parsed text of selected parts of a 35-page PDF: header/dates p. 30598, index 0; relevant introduction p. 30599, index 1; closed-end explanation pp. 30604–30605, indices 6–7; effective-date discussion p. 30618, index 20; selected amendatory instructions p. 30623, index 25; complete reprinted general §20(a) comments 1–5, pp. 30624–30625, indices 26–27. The five exception comments were read from S001, not assumed from omitted text here. No pixels viewed. |
| R035-P1-S018 | Federal Reserve Board and CFPB, Truth in Lending (Regulation Z), 90 FR 57882 | https://www.federalregister.gov/documents/2025/12/15/2025-22814/truth-in-lending-regulation-z https://www.govinfo.gov/content/pkg/FR-2025-12-15/pdf/2025-22814.pdf https://www.consumerfinance.gov/rules-policy/final-rules/truth-in-lending-regulation-z/ | Final annual threshold rule, published December 15, 2025, effective January 1, 2026. Read header/dates, adjustment explanation, operative 2026 threshold, and material closed-end exemption commentary. Parsed selected text of a 7-page PDF: Reg Z header begins on p. 57882, index 0; explanation p. 57883, index 1; Part 1026 amendatory language and threshold pp. 57886–57887, indices 4–5. Closed-end commentary on printed pp. 57887–57888 also read in HTML. The beginning of PDF index 0 contains preceding material; reliance starts at the Reg Z heading. No pixels viewed. No 2027 threshold is certified by this report. |
Claim ID · Supported finding and its limits · Exact authority · 8 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C001 | The retrieved eCFR body is a current compilation through October 26, 2026. Its statement that Title 12 was last amended October 23 does not identify the effective date of §20(a). The post-cutoff interval through the October 27 access remains unverified on an exhaustive publication-by-publication basis. | S001, eCFR currency/status notice and §20(a). ecfr.gov |
| R035-P1-C002 | The statutory snapshots used include laws through Public Law 119-121, October 9, 2026. They do not establish exhaustive review of enactments from October 10 through access, or of judicial developments. | S010–S014, OLRC snapshot notices. uscode.house.gov +2 |
| R035-P1-C003 | Supplement I is the CFPB’s published official interpretation vehicle. It should be distinguished from an examiner instruction, agency webpage explanation, circular, or advisory opinion. This report uses the regulation and official interpretations; it does not analyze the full consequences of reliance for liability or defenses. | S002, Introduction I-1–I-4. Consumer Financial Protection Bureau |
| R035-P1-C004 | The CFPB’s 2011 recodification was published December 22 and effective December 30, 2011. Its explanation that the transfer substantially duplicated the existing rule with technical changes is historical; it does not negate later amendments. | S015, summary and dates; historical §20(a) commentary. federalregister.gov +1 |
| R035-P1-C005 | The 2021 LIBOR final rule amended the closed-end official interpretation and generally became effective/compliant April 1, 2022. Its separate open-end notice and appendix transition dates are not alternative effective dates for the current §20(a) test. | S016, dates and §20(a) amendments. federalregister.gov +1 |
| R035-P1-C006 | The February 16, 2022 correction repaired two preamble hyperlinks. It did not create a new substantive §20(a) exception or change its refinancing test. | S016, complete correction. federalregister.gov |
| R035-P1-C007 | The 2023 LIBOR interim final rule, published May 11 and effective May 15, 2023, supplies the material current revisions to the comparable-index discussion, including Board-selected replacements. “Interim final” does not make the text merely proposed. | S017, dates, effective-date section, and amended comment 20(a)-3. govinfo.gov +2 |
| R035-P1-C008 | The annual final rule published December 15, 2025 establishes $73,400 as the §3(b) threshold for January 1–December 31, 2026, effective January 1, 2026. This is a legal coverage threshold, not a transaction amount, credit limit recommendation, or forecast for another year. | S018; S005, comment 3(b)-3.xvii. federalregister.gov +2 |
Claim ID · Supported finding and its limits · Exact authority · 15 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C009 | General Regulation Z coverage concerns credit offered or extended to consumers, regularly, subject to a finance charge or payable by written agreement in more than four installments, and primarily for personal, family, or household purposes. The creditor definition excludes a downpayment from that installment count. Specialized card and other provisions can have different scope; the four conditions are not a universal description of every provision in Regulation Z. | S003, §1(c)(1), (d); S004, §2(a)(17)(i). ecfr.gov +1 |
| R035-P1-C010 | “Credit” concerns the right to defer paying debt, or to incur debt and defer payment. A debt’s existence, a request for accommodation, or a label alone does not establish that a new credit transaction has been consummated. | S004, §2(a)(14), corresponding commentary; S010, §1602(f). ecfr.gov +2 |
| R035-P1-C011 | The ordinary consumer definition covers a cardholder or natural person to whom consumer credit is offered or extended. Guarantors, endorsers, and sureties generally are not consumers for ordinary purposes, subject to specified card/rescission contexts. The express confirmed-successor expansion covers §§20(c)–(e), 36(c), 39, and 41; it does not automatically establish §20(a)’s same-consumer predicate. Liability assumed under applicable law can affect other protections. | S004, §2(a)(11); comments 2(a)(11)-1–4. ecfr.gov +1 |
| R035-P1-C012 | Consumer credit requires a primary personal, family, or household purpose. The commentary supplies no single precise primary-purpose test. Certain consumer-purpose tax/estate-planning trusts and land trusts are treated as natural-person credit under the specified trust commentary; an organizational label alone does not resolve those cases. | S004, §2(a)(12), comments 2(a)(11)-3 and 2(a)(12)-1; S005, comment 3(a)-10; S010, §1602(i). Consumer Financial Protection Bureau +2 |
| R035-P1-C013 | Closed-end consumer credit is consumer credit that does not satisfy the open-end definition. Open-end credit requires a plan under which the creditor reasonably contemplates repeated transactions, may impose a finance charge from time to time on an unpaid balance, and generally makes credit available again as outstanding balances are repaid. All three elements matter. Actual repeated borrowing by every consumer is unnecessary; a finite series of advances is not automatically a replenishing plan. | S004, §2(a)(10), (20); complete comments 2(a)(20)-1–7. ecfr.gov +2 |
| R035-P1-C014 | The ordinary creditor test combines regular extension of qualifying consumer credit with the obligation being initially payable to that person, on the instrument or by agreement if no instrument exists. An assignment does not by itself change to whom the obligation was initially payable. This definition must be kept separate from §20(a)’s express inclusion of a holder or servicer. | S004, §2(a)(17)(i) and corresponding commentary; S010, §1602(g). ecfr.gov +2 |
| R035-P1-C015 | Ordinary regularity uses more than 25 qualifying extensions in the preceding calendar year, or more than five for dwelling-secured transactions. If the preceding-year standard was not met, the current calendar year is used. A separate rule covers more than one §32 extension in any 12-month period, or one or more such extensions through a mortgage broker. Special card-issuer provisions also exist. These are transaction/actor coverage tests, not renewal limits under §20(a). | S004, §2(a)(17)(iv)–(v), relevant counting commentary. ecfr.gov +1 |
| R035-P1-C016 | Business, commercial, agricultural, and specified organizational credit are excluded under §3(a). For credit financing an acquisition, the purpose commentary identifies occupation relationship, personal management, acquisition income relative to total income, transaction size, and stated purpose. Collateral’s personal character does not establish consumer purpose. Organizational credit is generally excluded even with a natural-person guarantor or security provider, subject to the trust qualification in C012. Rental-property purpose rules have additional predicates and are not reduced to a universal owner-occupied/consumer rule here. | S005, §3(a), comments 3(a)-1, -3–5, -8–10; S011, §1603(1). Consumer Financial Protection Bureau +2 |
| R035-P1-C017 | Formerly exempt business credit rewritten for consumer purposes requires consumer disclosures under the commentary only when the existing obligation is satisfied and replaced by a new consumer-purpose obligation undertaken by the same obligor, subject to the remaining coverage/exemption rules. Because the old business obligation was exempt, this is a distinct coverage issue; one should not assume §20(a)’s old-covered-obligation predicate. | S005, comment 3(a)-6; S001, §20(a). Consumer Financial Protection Bureau +1 |
| R035-P1-C018 | Part 1026 expressly excludes persons described in CFPA §1029. Section 5519 concerns defined motor-vehicle dealers predominantly engaged in sales and servicing or leasing and servicing, with exceptions for specified mortgage activities, vehicle credit not routinely assigned to an unaffiliated third party, and unrelated consumer-financial activities. It preserves other federal authority. Exclusion from CFPB Part 1026 cannot be equated with exemption from TILA generally; the Board’s Part 226 route remains a separate held inquiry. | S003, §1(c); S014, §5519(a)–(f); S018, agency-authority explanation. ecfr.gov +2 |
| R035-P1-C019 | For closed-end §3(b) coverage, the relevant extension of credit at consummation, or commitment at consummation to extend total credit, must exceed, not merely equal, the threshold then in effect. The exemption does not cover credit secured by any real property, personal property used or expected to be used as the consumer’s principal dwelling, or a defined private education loan. Subsequent paydown or a later threshold increase does not alone remove an exemption established at consummation. The measuring term is credit extended/committed, not an assumed cash-received or amount-financed figure. | S005, §3(b), comments 3(b)-5.i–ii and -7; S011; C008 for the 2026 amount. Consumer Financial Protection Bureau +2 |
| R035-P1-C020 | A replacement loan does not inherit an old loan’s threshold exemption: the new extension must qualify itself. Adding real-property or principal-dwelling security after consummation does not alone remove an existing closed-end loan’s §3(b) exemption, but principal-dwelling security has a separate rescission consequence under the referenced framework. Satisfaction and replacement by a newly secured loan is different: that new loan is not threshold-exempt. No actual security or rescission conclusion is made here. | S005, comments 3(b)-5.ii and -6.ii. Consumer Financial Protection Bureau |
| R035-P1-C021 | Other exemptions require their own conditions: public-utility credit with regulated/filed charges, not ordinary appliance/home-improvement finance; qualifying SEC/CFTC broker-dealer securities or commodities accounts, not every separate securities-purchase loan; qualifying home-fuel budget plans without a finance charge; loans made, insured, or guaranteed under Title IV of the Higher Education Act, not private education loans generally; and qualifying retirement-plan loans drawn from fully vested participant funds in the specified plans and made in compliance with the Internal Revenue Code. No generic “personal loan” label establishes or defeats these exemptions. | S005, §3(c)–(g), corresponding comments; S011, §1603. ecfr.gov +2 |
| R035-P1-C022 | Section 3(h) is a partial disclosure exemption for transactions meeting all its conditions, with an election between specified §18 and §19 disclosures. It does not exempt an otherwise covered transaction from all Regulation Z requirements or independently erase §20(a). Eligibility under its mortgage-assistance conditions remains held. Section 3(i)’s separate valuation provision also prevents treating §3 as a universal exemption from every part of the regulation. | S005, §3(h)–(i), comments 3(h)-1–5. ecfr.gov +1 |
| R035-P1-C023 | Consummation occurs when the consumer becomes contractually obligated on the credit transaction. Applicable state law determines that point. A fee, deposit, preliminary request, or purchase agreement does not necessarily establish credit consummation. No governing jurisdiction or contract is supplied here. | S004, §2(a)(13), comments 2(a)(13)-1–2; §2(b)(3). Consumer Financial Protection Bureau +1 |
Claim ID · Supported finding and its limits · Exact authority · 11 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C024 | The general §20(a) test requires an existing obligation that was subject to Subpart C, its satisfaction and replacement, and a new obligation undertaken by the same consumer. The official interpretation requires complete replacement of the prior obligation. All predicates must be established before applying this general classification. | S001, §20(a), comment 20(a)-1. ecfr.gov +1 |
| R035-P1-C025 | Satisfaction/extinguishment and replacement are determined from the contract and applicable law. Consolidation, new-money disbursement to the consumer or on the consumer’s behalf, or rescheduling can be forms of refinancing, but the form or label is not the legal test. “Modification,” “novation,” “rewrite,” “replacement,” “extension,” and similar labels cannot substitute for that inquiry. | S001, comment 20(a)-1; S004, §2(b)(3). Consumer Financial Protection Bureau +1 |
| R035-P1-C026 | Merely changing terms, including deferring individual installments, is not refinancing under the general test without cancellation and substitution. Conversely, a substitution that satisfies the definition can require new disclosures even without a substantial change in credit terms. The separate variable-rate rule in C031 must still be considered. | S001, comment 20(a)-1.i–ii and -3.ii. Consumer Financial Protection Bureau |
| R035-P1-C027 | The five statutory-regulatory exception events in §20(a)(1)–(5) are not treated as refinancings even if accomplished by cancelling the old obligation and substituting a new one. Failure to satisfy one exception is not, alone, a complete affirmative refinancing conclusion: coverage, the general test, other applicable exceptions, and the variable-rate commentary must still be considered. | S001, comment 20(a)-2; §20(a)(1)–(5). The final sentence is the logical application of that structure. Consumer Financial Protection Bureau +1 |
| R035-P1-C028 | Section 20(a) applies to transactions undertaken by the original creditor, a holder, or a servicer of the original obligation. The word “successor” alone does not establish which role exists. The original-creditor/successor rule in the separate rescission commentary must not be substituted for this broader express coverage language. | S001, comment 20(a)-5; S009, comment 23(f)-4. Consumer Financial Protection Bureau +1 |
| R035-P1-C029 | A “refinancing” undertaken by any other person is a new transaction under Regulation Z, rather than refinancing under §20(a). Its coverage and applicable new-transaction disclosures must be evaluated independently. This classification does not establish payoff, closing of the old arrangement, release of an obligor, or lien discharge. | S001, comment 20(a)-5; S003–S005 for coverage. Consumer Financial Protection Bureau +1 |
| R035-P1-C030 | A rate change conforming to a properly disclosed variable-rate feature is not a refinancing. The official example is invocation of such a feature on a renewable balloon-payment mortgage previously disclosed as a variable-rate transaction. The predicates are the prior proper disclosure and conformity of the change; the example supplies no blanket exemption for balloon extensions. | S001, comment 20(a)-3.i; E002. Consumer Financial Protection Bureau |
| R035-P1-C031 | Even without cancelling and replacing the old obligation, a new transaction requiring new disclosures results if the creditor increases the rate using a variable-rate feature not previously disclosed, or adds a variable-rate feature. The comparable-index qualification in C032 limits what counts as adding such a feature. | S001, comment 20(a)-3.ii.A–B. Consumer Financial Protection Bureau |
| R035-P1-C032 | Changing a variable-rate index to a comparable index does not itself add a variable feature, whether replacing an existing index or an index that no longer exists. The current official example treats the 1-, 3-, 6-, and 12-month U.S. dollar LIBOR tenors as comparable to their respective Board-selected consumer-loan benchmark replacements. Section 2(a)(28) supplies the definition; this report does not reconstruct Part 253 or calculate an actual replacement rate. | S001, comment 20(a)-3.ii.B; S004, §2(a)(28); S017; E003. Consumer Financial Protection Bureau +2 |
| R035-P1-C033 | For a proposed LIBOR replacement other than the specified Board-selected replacement, relevant comparability factors are nonexclusive: movements over time, comparable payments if sufficient data exist, index levels, public availability, and independence from creditor control. Historical-data timing may need adjustment when comparing backward-looking and forward-looking rates. The specified Board-selected replacement is deemed comparable for its corresponding tenor, without that factor analysis. | S001, complete comment 20(a)-3.iv. Consumer Financial Protection Bureau |
| R035-P1-C034 | If either C031 event occurs in a transaction secured by a principal dwelling with a term longer than one year, the commentary additionally requires the §19(b) disclosures at that time. That is a precise product/term cross-reference, not a complete ARM-notice or mortgage-disclosure analysis. | S001, comment 20(a)-3.iii. Consumer Financial Protection Bureau |
Claim ID · Supported finding and its limits · Exact authority · 18 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C035 | The single-payment exception requires renewal with no change in original terms, subject to the commentary’s specified tolerances. It covers both a single payment of principal and interest and periodic interest payments followed by a final principal payment. It is not an exception for every installment-loan maturity extension. | S001, §20(a)(1), comment 20(a)(1)-1. ecfr.gov +1 |
| R035-P1-C036 | In deciding whether a replacement is a renewal on original terms, the creditor may still treat it as a renewal where accrued unpaid interest is added to principal, changes result from §17(c)(3)’s listed minor factors, or principal is reduced by a curtailment. These specific allowances do not establish a general exemption for any new fee, advance, or capitalized amount. | S001, comment 20(a)(1)-1.i–iii; E005. Consumer Financial Protection Bureau |
| R035-P1-C037 | The incorporated §17(c)(3) factors are: collection in whole cents; changing a scheduled payment/advance date because it is not a business day; differing numbers of days in months; and leap year. The renewal comment cites (c)(3), not every calculation tolerance elsewhere in §17(c). | S007, §17(c)(3)(i)–(iv); S001, comment 20(a)(1)-1.ii. ecfr.gov +1 |
| R035-P1-C038 | The complete §20(a) text and commentary contain no express numerical cap on successive single-payment renewals and no specified elapsed-time allowance for repeated renewals. That textual finding is not unlimited rollover authorization: each event must satisfy the applicable test, and contractual authority and other law remain unresolved. | S001, complete §20(a) and commentary, particularly (1) and general comment -3. ecfr.gov +1 |
| R035-P1-C039 | The APR-reduction exception requires an actual reduction in APR with a corresponding payment-schedule change. The commentary identifies shortening maturity, reducing the payment amount, or reducing the number of payments as corresponding changes implementing the reduction. | S001, §20(a)(2), comments 20(a)(2)-1–2. ecfr.gov +1 |
| R035-P1-C040 | This exception does not apply if maturity is lengthened, or the payment amount or number of payments exceeds what remains on the existing transaction. A lower installment accompanied by a longer maturity therefore does not establish this exception. | S001, comment 20(a)(2)-2. Consumer Financial Protection Bureau |
| R035-P1-C041 | If APR is later increased and the increase is accomplished through satisfaction and replacement, the APR-reduction commentary requires new disclosures even when the increased APR remains below the original APR. The comparison is not simply with the transaction’s first-ever rate. Any independently applicable exception still needs separate consideration. | S001, comment 20(a)(2)-1, read with general comment -2. Consumer Financial Protection Bureau |
| R035-P1-C042 | The court exception concerns an agreement involving a court proceeding. Its official examples include reaffirmations of debts discharged in bankruptcy, settlement agreements, and post-judgment agreements. The court-proceeding predicate cannot be dropped to create a general exception for private settlements or all workouts. | S001, §20(a)(3), comment 20(a)(3)-1; E006. ecfr.gov +1 |
| R035-P1-C043 | The credit definition separately excludes court judgments and court approvals of reaffirmations of debts discharged in bankruptcy. Financing such an obligation by a third party can constitute credit. Thus a court-related arrangement may require both a threshold credit inquiry and, if otherwise relevant, the §20(a)(3) exception inquiry. No bankruptcy or proceeding-specific determination is made. | S004, comment 2(a)(14)-1.ii; S001, comment 20(a)(3)-1. Consumer Financial Protection Bureau +1 |
| R035-P1-C044 | The default/delinquency exception applies to a change in the payment schedule or collateral requirements as a result of the consumer’s default or delinquency. A voluntary hardship request, anticipated difficulty, or use of the word “workout” does not itself establish that causal and status predicate. | S001, §20(a)(4), comment 20(a)(4)-1. ecfr.gov +1 |
| R035-P1-C045 | An increased rate defeats this exception; the official workout commentary expresses the test as an APR increase. It is unsafe to examine only the nominal interest rate while ignoring a fee’s possible effect on APR. The disclosure tolerances in §22 are not an allowance to increase APR while retaining the §20(a)(4) exception. | S001, §20(a)(4), comment 20(a)(4)-1; S019, §22(a). The tolerance distinction follows from the different provisions’ subjects. ecfr.gov +2 |
| R035-P1-C046 | The exception also fails if the new amount financed exceeds the unpaid balance plus earned finance charge plus premiums for continuation of insurance of the types described in §4(d). The commentary summarizes this as additional credit beyond amounts already accrued plus insurance premiums. The measuring amount is not merely new cash delivered to the consumer. The word “continuation” and the §4(d) type limitation must be retained. | S001, §20(a)(4), comment 20(a)(4)-1; S006, §4(d). ecfr.gov +2 |
| R035-P1-C047 | Section 20(a)(4) contains no general “reasonable refinancing costs” addition to that comparison base. Section 23(f)(2) separately addresses rescission for a same-creditor refinancing of credit already secured by the principal dwelling, using unpaid principal, earned unpaid finance charge, and costs attributable solely to refinancing. Comment 23(f)-4 includes qualifying bona fide/reasonable §4(c)(7) fees and other specified non-finance-charge costs in that separate inquiry; it also defines original creditor and specified institutional successors for that purpose. Those rules cannot be imported into §20(a)(4). | S001, §20(a)(4); S009, §23(f)(2), complete comment 23(f)-4. ecfr.gov +2 |
| R035-P1-C048 | The insurance exception requires renewal of optional insurance purchased by the consumer, added to the existing transaction, with the required disclosures relating to the initial purchase having been provided. A charge being called insurance, a new insurance purchase, or evidence only of renewal disclosures does not establish all these conditions. | S001, §20(a)(5), comment 20(a)(5)-1. ecfr.gov +1 |
| R035-P1-C049 | The separate §4(d)(1) finance-charge exclusion for credit life, accident, health, or loss-of-income insurance requires that coverage not be required, written disclosure of that fact and the initial premium, disclosure of a shorter coverage term, and a signed or initialed affirmative request after the disclosures. Any consumer in the transaction may request it. Unit-cost disclosure is permitted only in the specified open-end, §17(g) mail/telephone, or coverage-limited closed-end situations. Optional status is factual; the §4(d)(4) telephone alternative is confined to open-end, non-home-secured plans. | S006, §4(d)(1), (4); comments 4(d)-4–7, -13. These are finance-charge conditions, not additional unwritten conditions added to §20(a)(5). ecfr.gov +2 |
| R035-P1-C050 | For the separate property/liability-insurance exclusion, the consumer must be permitted to choose the insurer and that choice must be disclosed; reasonable-cause rejection of an offered insurer is allowed. If coverage is obtained through the creditor, initial premium and any shorter term must be disclosed, subject to the stated unit-cost limits. Qualifying single-interest insurance additionally requires waiver of subrogation. Nonqualifying extra coverages generally require premium allocation; the commentary’s narrow de minimis exception is an attributable total of no more than $1, or $5 for a multiyear policy. This does not establish that insurance is optional for §20(a)(5). | S006, §4(d)(2); comments 4(d)-8–10. ecfr.gov +1 |
| R035-P1-C051 | Section 4(d)(3) separately addresses specified voluntary debt-cancellation/suspension coverage. Exclusion requires written optional-status and initial-cost/shorter-term disclosures, the applicable suspension-only and continuing-interest explanations, and an affirmative signed/initialed request after disclosure; unit-cost use is limited as specified. For combined events at one charge, the commentary permits exclusion if at least one covered event is accident or loss of life, health, or income and the required conditions are met. Section 4(d)’s contextual use of “insurance” includes these products unless context indicates otherwise; that does not establish a universal §20(a)(5) exemption for every cancellation/suspension arrangement. | S006, §4(d)(3); comments 4(d)-1 and 4(d)(3)-1–4. ecfr.gov +1 |
| R035-P1-C052 | For §4(d), initial term is the period the insurer/creditor is bound to provide coverage, even if the consumer can cancel or nonpayment can terminate it. A single premium paid or financed in advance generally covers the full credit term. A clearly labeled one-year cost disclosure may replace a longer initial term when that term is indefinite/unclear or periodically charged coverage may be discontinued without obligation. Separate commentary permits certain premium changes without redisclosure solely to preserve finance-charge exclusion. Those rules do not waive §20(a)(5)’s initial-disclosure predicate. | S006, comments 4(d)-2–3 and -11–12. Consumer Financial Protection Bureau |
Claim ID · Supported finding and its limits · Exact authority · 9 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C053 | In a refinancing involving precomputed charges, unearned prior finance charge that is neither rebated to the consumer nor credited against the underlying obligation must be included in the new finance charge and reflected in the new APR. Calling it principal or capitalizing it does not remove this treatment. The rule does not itself establish a universal right to a rebate. A cash rebate and a credit to the old obligation must not be assumed to have identical accounting or cash-flow effects. | S001, §20(a), comment 20(a)-4; E004. ecfr.gov +1 |
| R035-P1-C054 | Accrued but unpaid finance charges are included in the amount financed of the new obligation. This is expressly distinguished from the unearned prior charge in C053. The word “capitalized” alone does not reveal which category an amount occupies. | S001, final sentence of comment 20(a)-4. Consumer Financial Protection Bureau |
| R035-P1-C055 | Finance charge is the dollar cost of consumer credit, including charges imposed directly or indirectly as an incident to or condition of credit, subject to stated exclusions. Comparable charges payable in a cash transaction are treated differently. Interest, add-on/discount charges, points, and loan fees are listed examples, subject to applicable exclusions. Payment to a third party or use of a “cost reimbursement” label does not itself settle classification. | S006, §4(a), (b)(1), (3), corresponding general commentary; S012, §1605(a). ecfr.gov +2 |
| R035-P1-C056 | An application fee is excluded under §4(c)(1) when charged to all applicants, whether credit is extended or not. Section 4(c)(2) concerns actual unanticipated late payment, delinquency, default, or similar events. Neither provision supplies a blanket exclusion for a fee charged only on successful refinancing or for any planned deferral/workout charge. Actual terms and practices matter. | S006, §4(c)(1)–(2), corresponding complete comments. ecfr.gov +1 |
| R035-P1-C057 | Section 4(c)(7) excludes specified bona fide, reasonable fees in real-property-secured or residential-mortgage transactions: title/survey-related fees; loan-document preparation; notary/credit-report fees; qualifying preclosing appraisals/inspections; and escrow amounts otherwise outside finance charge. The commentary limits the exclusion to the initial credit decision, addresses allocation of mixed charges, and allows a specified predominantly qualifying closing-service lump sum to include incidental services. Periodic services during the loan term are not brought within the exclusion merely by prepayment. This is a finance-charge rule, not a general allowance in the §20(a)(4) amount-financed base. | S006, §4(c)(7)(i)–(v), comments 4(c)(7)-1–3. ecfr.gov +2 |
| R035-P1-C058 | Section 18(b) determines amount financed by starting with the principal loan amount—or cash price less downpayment for a credit sale—adding financed amounts that are not finance charges and are not already included, and subtracting prepaid finance charges as prescribed. It therefore need not equal the note’s face amount, old payoff amount, or new cash received. | S008, §18(b)(1)–(3), comments 18(b), 18(b)(2)-1; S013, §1638(a)(2). ecfr.gov +2 |
| R035-P1-C059 | A prepaid finance charge is paid separately in cash/check before or at consummation, or withheld from proceeds at any time. Precomputed add-on or discount finance charges are not prepaid merely because they are calculated in advance. Correct treatment depends on the charge and how it enters the transaction. | S004, §2(a)(23), complete corresponding commentary. ecfr.gov +1 |
| R035-P1-C060 | For financed finance charges other than add-on/discount charges, the §18(b)(3) commentary permits a principal starting amount that includes or excludes the charge. If included, the prepaid charge is deducted; if excluded, it must not be deducted again. The choice of presentation does not change its finance-charge character. Add-on/discount charges require their own stated treatment. | S008, comments 18(b)(3)-1.i–iv and -2.i–iii. Consumer Financial Protection Bureau +1 |
| R035-P1-C061 | The amount-financed itemization distinguishes amounts paid directly to the consumer, credited to the consumer’s debt with the creditor, paid to other persons, and prepaid finance charges. Section 18(c) permits the specified written-request alternative to automatically furnishing the separate itemization; if requested, it must be provided. A credit to an existing debt is not automatically cash received. Specialized mortgage alternatives remain held. | S008, §18(c), complete material commentary, particularly 18(c)(1)(i)–(iv). Consumer Financial Protection Bureau +1 |
Claim ID · Supported finding and its limits · Exact authority · 16 data rows
| Claim ID | Supported finding and its limits | Exact authority |
|---|---|---|
| R035-P1-C062 | The direct new-disclosure basis is §20(a), amplified by comment 20(a)-1’s requirement for a complete new set. TILA §1638 and the applicable Regulation Z disclosure provisions supply the content and timing. The new disclosure is not limited to the amount of cash newly advanced. | S001, §20(a), comment -1; S013, §1638(a), (b)(1); S007–S008. Consumer Financial Protection Bureau +2 |
| R035-P1-C063 | Section 18 applies to covered closed-end transactions outside §19(e)/(f), with disclosures only as applicable. Its commentary identifies unsecured credit, non-dwelling personal-property credit, certain personal-property dwellings, and reverse mortgages as relevant categories, with different payment-disclosure forms. Ordinary real-property/cooperative-unit transactions route to §19(e)/(f), subject to stated exceptions and the qualifying §3(h) election. This pass identifies that boundary without completing mortgage disclosure requirements. | S008, general comments 18-1 and -3; S005, comment 3(h)-1. Consumer Financial Protection Bureau +1 |
| R035-P1-C064 | Under the ordinary §17(a) route, disclosures must be clear, conspicuous, written, and retainable. Electronic delivery is subject to the incorporated E-SIGN requirements, with specified exceptions. Grouping, segregation, and prominence rules apply; specified creditor, insurance, security-charge, and other items may be separate. The §19(e)/(f)/(g) and private-education qualifications must not be omitted. Full E-SIGN and product-form compliance remain held. | S007, §17(a)(1)–(2). ecfr.gov |
| R035-P1-C065 | The ordinary timing rule is before consummation. Section 17(b) expressly identifies special residential-mortgage, variable-rate, private-education, and mail/telephone or series-of-sales timing, and excludes specified §19 and §20(e) disclosures from its own timing rule. No actual calendar deadline can be derived without the applicable route and consummation facts. | S007, §17(b); S004, §2(a)(13); S013, §1638(b)(1). ecfr.gov +2 |
| R035-P1-C066 | Section 17(g)’s delay to the first payment’s due date requires a purchase order or credit request by mail, telephone, or fax without face-to-face or direct telephone solicitation, and prior written/electronic availability of the listed representative credit information: principal/cash price, total sale price, finance charge, APR and applicable increase circumstances/limits/effect, and repayment terms. It excludes the identified mortgage and private-education disclosures. It is not a general exception for every remote application. | S007, complete §17(g)(1)–(5) and corresponding commentary. ecfr.gov |
| R035-P1-C067 | Section 17(h)’s series-of-sales delay requires an agreement permitting later credit sales to be added to the balance; written consumer approval of APRs, applicable balance ranges, and treatment of unearned charges; and no retained security in an item after receipt of its cash price and attributable finance charge. For that security condition, older purchases are paid first, and same-day purchases are ordered by lowest price first. The delay ends at the current sale’s first-payment due date; the specified mortgage disclosures are excluded. This is not a universal refinance payment-allocation rule. | S007, complete §17(h)(1)–(2). ecfr.gov |
| R035-P1-C068 | Disclosures reflect the legal obligation. Unknown necessary information ordinarily uses the best reasonably available information and must be clearly labeled as an estimate. The rule separately addresses per-diem interest collected at consummation, allowing affected disclosures to use information known when the consummation documents are prepared. These provisions do not authorize invented terms or substitute for an actual agreement. | S007, §17(c)(1)–(2), corresponding legal-obligation and estimate commentary. ecfr.gov +2 |
| R035-P1-C069 | For ordinary early disclosures, §17(f) requires changed terms before consummation unless the stated estimate qualification applies; all changed terms must be redisclosed if APR differs by more than 1/8 percentage point for a regular transaction or 1/4 percentage point for an irregular transaction, subject to the stated mortgage/private-education qualifications. Irregularity concerns multiple advances or irregular payment periods/amounts, excluding merely an irregular first period or first/final payment. A variable-rate feature does not itself make an initially regular amortization schedule irregular. These are disclosure rules, not §20(a)(4) rate-increase permissions. | S007, §17(f)(1)–(2); S019, §22(a)(2)–(3), comments 22(a)(2)-1 and 22(a)(3)-1. ecfr.gov +2 |
| R035-P1-C070 | A later event making an earlier disclosure inaccurate does not itself make that disclosure a violation under §17(e), but new disclosures may nevertheless be required by §17(f), §19, §20, or the identified private-education provision. Earlier accurate disclosures therefore do not establish that a later replacement needs none. | S007, §17(e). ecfr.gov |
| R035-P1-C071 | A complete applicable §18 set includes the creditor, amount financed and relevant itemization, finance charge, APR, applicable variable-rate information, payment schedule/total, and applicable prepayment, late-payment, security, insurance, security-cost, contract-reference, demand, required-deposit, credit-sale, or mortgage-related information. “As applicable” is substantive: total sale price is a credit-sale disclosure, and the late-payment provision distinguishes late charges from deferral/extension charges. Listing a category does not establish that it applies to an unknown transaction. | S008, §18(a)–(r), general comments 18-1–3; S013, §1638(a)(1)–(13). ecfr.gov +3 |
| R035-P1-C072 | Two material qualifications prevent universal numeric-disclosure statements: §18(e) permits omission of APR where finance charge does not exceed $5 when amount financed is $75 or less, or $7.50 when amount financed exceeds $75; §18(h) does not require total-of-payments disclosure for a single-payment transaction. These are legal disclosure thresholds and exceptions, not illustrative loan terms. | S008, §18(e), (h). ecfr.gov +1 |
| R035-P1-C073 | Multiple creditors provide one set and agree who complies. With multiple consumers, ordinary disclosures may be made to any consumer primarily liable; where the transaction is rescindable, disclosures must reach each consumer entitled to rescind. This delivery rule does not resolve who is liable or whether the same-consumer refinancing predicate is met. | S007, §17(d). ecfr.gov |
| R035-P1-C074 | A disclosure classification presupposes the legally established transaction; furnishing a new disclosure is not itself proof of satisfaction, release, novation, lien termination, guarantor discharge, or closure of another credit arrangement. Security disclosure under §18(m) reports the relevant security interest; it does not perform a release. These questions require the contract and applicable law that are absent here. | S001, comment 20(a)-1; S004, §2(a)(25), (b)(3); S008, §18(m), (p). This is a limit on what those provisions establish. Consumer Financial Protection Bureau +2 |
| R035-P1-C075 | The selected classification and disclosure provisions do not themselves require a creditor to offer refinancing, accept an application, approve a concession, make an affordability finding, or promise particular terms. They also do not establish that an unknown transaction is enforceable or beneficial. This conclusion is limited to the selected provisions, not a claim that no other law supplies obligations. | S001, §20(a); S003, §1(b)–(d); S007–S008. ecfr.gov +2 |
| R035-P1-C076 | A lower installment does not establish a lower total cost. The required disclosure structure distinguishes APR, finance charge, payment amount, payment count/timing, and total payments. Without those separate inputs and the applicable fee treatment, a savings conclusion does not follow. This is an inference from the disclosed quantities, not a forecast. | S008, §18(d)–(h); S013, §1638(a). ecfr.gov +2 |
| R035-P1-C077 | An open-end balance transfer is outside the selected closed-end refinancing classification. Repayment of a balance does not, from the open-end definition alone, prove termination of the replenishing plan. Actual conversion to closed-end credit has separate commentary under §17(b); ordinary scheduled repayment under an existing plan cannot simply be relabeled a new §20(a) refinancing. Full open-end transfer, conversion, and card rules remain held. | S004, §2(a)(10), (20), corresponding commentary; S007, comment 17(b)-2. Consumer Financial Protection Bureau +2 |
Provision · Cumulative conditions for the stated treatment · Qualification or exception to the exception · 6 data rows
| Provision | Cumulative conditions for the stated treatment | Qualification or exception to the exception | Consequence and evidence |
|---|---|---|---|
| §20(a)(1): single-payment renewal | Qualifying single-payment structure; renewal on original terms. Includes periodic interest with final principal. | Permitted accrued-interest capitalization, principal curtailment, and only the incorporated §17(c)(3) factors. Other changed terms/new funds require analysis. No express renewal-count cap or blanket rollover authorization. | If all conditions hold, not treated as refinancing even with replacement. C035–C038; S001/S007; E005. |
| §20(a)(2): APR reduction | Reduced APR plus a corresponding schedule change implementing it. | Shorter maturity, lower installment, or fewer payments can correspond. Longer maturity or increased remaining payment amount/count defeats this exception. A later replacement with an APR increase can require new disclosures even below the first APR. | No inference from “lower payment” alone. C039–C041; S001. |
| §20(a)(3): court agreement | Agreement involving a court proceeding. | The official categories are examples within that predicate. Some judgments/court approvals are separately outside “credit”; third-party financing can still be credit. | A private settlement label is insufficient. C042–C043; S001/S004; E006. |
| §20(a)(4): default/delinquency workout | Schedule or collateral change resulting from default/delinquency; no APR increase; new amount financed does not exceed the precise unpaid-balance/earned-charge/continuation-premium base. | An APR increase or excess amount financed defeats this exception. No general reasonable-cost allowance appears here. Noncash financed charges can matter. | Neither “no cash out” nor “hardship” proves the exception. C044–C047; S001/S006/S009. |
| §20(a)(5): optional-insurance renewal | Renewal, optional insurance bought by the consumer, addition to the existing transaction, and required initial-purchase disclosures previously supplied. | Optional status, renewal status, and initial disclosure compliance cannot be assumed. Separate §4(d) fee-exclusion tests do not establish all these predicates. | A new insurance purchase or unspecified premium capitalization is not automatically within the exception. C048–C052; S001/S006. |
| Comment 20(a)-3: variable-rate treatment | Properly disclosed feature and conforming change avoid refinancing treatment; a comparable index change does not add a feature. | Undisclosed-feature increase or addition of a variable feature independently requires new disclosures even without replacement. Specified principal-dwelling/term cases also invoke §19(b). | This commentary qualification must be checked alongside the general replacement test. C030–C034; S001/S004/S017; E002–E003. |
Example ID · Complete material proposition illustrated · Conditions preserved; evidentiary limit · 6 data rows
| Example ID | Complete material proposition illustrated | Conditions preserved; evidentiary limit |
|---|---|---|
| E001 | Comment 20(a)-1 contrasts deferral of individual installments with cancellation/substitution and explains that even substantially unchanged replacement terms can trigger disclosures. | Contract and applicable law determine whether complete replacement occurred. C024–C026; S001. |
| E002 | Comment 20(a)-3.i uses a renewable balloon-payment mortgage whose variable feature had previously been properly disclosed. | Only a change conforming to that disclosed feature receives the stated treatment. No blanket mortgage-renewal or maturity-extension result. C030; S001. |
| E003 | Comment 20(a)-3.ii.B uses the corresponding Board-selected replacement for each specified LIBOR tenor. | Correct tenor and defined replacement matter. Other replacements use the qualified comparability analysis. No actual index or rate was calculated. C032–C033; S001/S004/S017. |
| E004 | Comment 20(a)-4 describes an add-on-charge transaction replaced with new money, without refund or credit of the old unearned charge. | The old unearned charge enters the new finance charge and APR; accrued unpaid charges receive different treatment. No refund entitlement or amount is inferred. C053–C054; S001. |
| E005 | Comment 20(a)(1)-1 expressly allows the stated accrued-interest addition, minor-factor changes, and principal curtailment within the renewal analysis. | The underlying qualifying single-payment/original-terms requirement remains. C035–C037; S001/S007. |
| E006 | Comment 20(a)(3)-1 gives reaffirmation, settlement, and post-judgment examples. | Court involvement remains necessary; the separate credit-definition issue remains. No case, filing, or actual agreement was examined. C042–C043; S001/S004. |
Branch / status · Conditional supported rule and evidence · Missing evidence · 27 data rows
| Branch / status | Conditional supported rule and evidence | Missing evidence | Adverse inference to avoid | Next permissible public-law inquiry |
|---|---|---|---|---|
| B001 — Partial: coverage/purpose unknown | Apply consumer-purpose, creditor, closed-end, and exemption predicates before §20(a). C009–C022; S003–S005/S010–S014. | Purpose, actor status, structure, exemption facts. | A personal-sounding label proves consumer coverage. | Examine the relevant generic §2 definition and §3 exemption/comment once the legal category is identified. |
| B002 — Partial: original creditor/holder/servicer/successor unknown | Section 20(a) expressly includes original creditor, holder, or servicer; “successor” alone does not resolve the role. C014, C028; S001/S004/S009. | Legal role and succession basis. | Every new brand is a new creditor, or every successor is automatically the original creditor for all provisions. | Compare comment 20(a)-5 with the distinct comment 23(f)-4 only for their respective purposes. |
| B003 — Partial: same consumer unknown | The general test requires the same consumer; confirmed-successor provisions do not automatically answer it. C011, C024, C073; S001/S004/S007. | Obligors, legal capacity, any assumption/substitution. | Ownership transfer, a guaranty, or receipt of notices establishes the same-consumer predicate. | Review §2(a)(11) and comment 20(a)-1; preserve §20(b) as a separate held route. |
| B004 — Partial: satisfaction/replacement unknown | Complete legal replacement is essential to the general test. C024–C026; S001/S004. | Contractual effect and applicable law. | A new schedule, statement, signature page, or document title necessarily extinguishes the old obligation. | Revisit comment 20(a)-1’s legal test; governing-law research remains parent-held. |
| B005 — Partial: label differs from substance | Consolidation, modification, renewal, rewrite, novation, or refinancing terminology is not dispositive. C025–C027; S001. | Legal substance of the change. | The heading on a document controls federal classification. | Compare the generic legal effects with §20(a) and each applicable exception. |
| B006 — Partial: new lender | A person outside original-creditor/holder/servicer coverage undertakes a new transaction under Regulation Z rather than a §20(a) refinancing. C029, C062–C065; S001/S007/S008/S013. | New actor’s creditor status, coverage, consummation, applicable route. | Outside §20(a) means no new disclosures or automatic old-debt release. | Apply §§1–3, then the appropriate new closed-end disclosure provisions. |
| B007 — Partial: single-payment renewal | The exception covers specified single-payment structures renewed on original terms, with only the stated allowances. C035–C037; S001/S007; E005. | Original payment structure and renewal terms. | Any balloon extension or installment-loan extension is exempt. | Read §20(a)(1), its complete comment, and §17(c)(3) together. |
| B008 — Partial: changed original terms | Changes beyond the express renewal allowances require renewed analysis; other exceptions/general predicates still matter. C027, C035–C037; S001/S007. | Nature of changed rate, fees, maturity, principal, or payment structure. | Any change automatically is refinancing, or any unchanged nominal rate preserves renewal status. | Identify which exact exception, if any, addresses that type of change. |
| B009 — Partial: successive renewals/variable feature | No express §20(a) renewal-count cap was found; each event remains subject to its conditions and the variable-rate rules. C030–C038; S001/S004/S017. | Prior disclosure and renewal terms; feature/index changes. | No written count limit means an entitlement to unlimited renewals. | Examine comments 20(a)-3 and 20(a)(1)-1; use the public index-definition cross-reference only if necessary. |
| B010 — Partial: lower APR/payment schedule | Reduced APR requires a corresponding schedule change; longer maturity or increased remaining amount/count defeats this exception. C039–C041; S001. | Old remaining schedule and revised APR/schedule. | A smaller installment proves exemption or savings. | Apply comment 20(a)(2)-2’s remaining-obligation comparison. |
| B011 — Partial: court proceeding | Court involvement is required; credit-definition exclusions may independently matter. C042–C043; S001/S004; E006. | Legal nature of the agreement and proceeding connection. | All settlements, reaffirmations, or collection compromises receive the same classification. | Review §20(a)(3) and comment 2(a)(14)-1.ii generically; no case search. |
| B012 — Partial: default/delinquency | The schedule/collateral change must result from default or delinquency, with both rate and amount conditions satisfied. C044–C046; S001. | Status, causal basis, rate and financed components. | Hardship, anticipated difficulty, or a request proves default and exception eligibility. | Revisit the full text of §20(a)(4), without inventing a delinquency clock. |
| B013 — Partial: rate increase | APR increase defeats the workout exception; later increased APR through replacement also defeats reliance on the reduction exception as stated. C041, C045; S001. | Correct old/new APR and charge treatment. | An unchanged nominal interest rate proves unchanged APR; §22 tolerance permits an increase. | Use §§4, 18, and the narrowly relevant §22 rules to distinguish charge classification from rate permission. |
| B014 — Partial: new advance | Section 20(a)(4) compares new amount financed with the specified base; no-cash-out is insufficient. C046, C054, C058–C061; S001/S004/S008. | All financed components and any existing amounts accrued. | Only cash delivered is additional credit. | Apply the §18(b) amount-financed method and then the separate §20(a)(4) comparison. |
| B015 — Partial: claimed reasonable costs | No general reasonable-cost addition appears in §20(a)(4). The §4(c)(7) and §23(f)(2) tests serve different purposes. C047, C057; S001/S006/S009. | Cost type, legal authorization, finance-charge status, purpose. | “Reasonable” or “bona fide” automatically preserves the workout exception. | Read the applicable fee provision and keep the separate rescission calculation bounded. |
| B016 — Partial: optional-insurance renewal | Renewal, optional purchase, addition to the existing transaction, and compliant initial disclosures must all be established. C048–C052; S001/S006. | Optional status, initial disclosures, renewal versus new coverage, type/term. | Any premium financing or §4(d) exclusion proves §20(a)(5). | Compare §20(a)(5) with the applicable complete §4(d) provision/comment. |
| B017 — Partial: old unearned finance charge | Unrebated/uncredited unearned prior charge enters the new finance charge/APR. C053; S001; E004. | Earned/unearned decomposition and actual rebate/credit treatment. | Capitalization converts all prior charges into new amount financed. | Apply comment 20(a)-4 before the §18(b) calculation. |
| B018 — Partial: capitalized arrears versus cash | Accrued unpaid finance charges enter new amount financed; other fees and unearned amounts require separate classification. C054–C061; S001/S004/S006/S008. | Principal, earned interest, unearned charge, fees, financed costs, disbursement categories. | “Arrears,” “principal,” or “capitalized” is a complete regulatory classification. | Use §4, §2(a)(23), and §18(b)/(c) by component. |
| B019 — Partial: added/released collateral | Collateral change can fit §20(a)(4) only with its default/delinquency and financial conditions; threshold and rescission consequences are separate. C020, C044–C047, C074; S001/S005/S009. | Existing/new security and legal effect. | Added collateral always is refinancing, or revised disclosures release an existing lien. | Compare comments 3(b)-6.ii and 20(a)-1 with §20(a)(4); retain full rescission/lien law as held. |
| B020 — Partial: open-end transfer or still-open arrangement | Closed-end status depends on the plan definition; payoff does not establish closure. Full balance-transfer treatment lies elsewhere. C013, C077; S004/S007. | Plan terms, replenishment, whether a new closed-end agreement exists. | A transferred or zero balance proves a closed account or §20(a) refinancing. | Review §2(a)(20) and identify the separate Subpart B or conversion route without applying it here. |
| B021 — Excluded: mortgage/assumption/rescission framework | Section 20(a) classification does not resolve §20(b) assumption, mortgage form/timing, ARM notices, or rescission. C034, C047, C063–C065, C074; S001/S007–S009. | Product, security, consumer identity, timing, and transaction type. | New disclosures establish an assumption, rescission right, waiver, or lien discharge. | If the parent hold is released, investigate the specific §19, §20(b)–(e), §23, or mortgage-subpart branch separately. |
| B022 — Partial: lower installment/longer term/total cost | Lower payment alone is not savings; longer maturity also defeats the APR-reduction exception. C040, C076; S001/S008/S013. | Entire schedule, term, charges, rate treatment, final payment. | Lower monthly burden necessarily lowers finance charge or total payments. | Examine only the applicable disclosure quantities; no amortization forecast without complete assumptions. |
| B023 — Partial: contractual release unknown | Classification does not adjudicate obligor, guarantor, lien, or account release. C024–C026, C074; S001/S004/S008. | Governing law and legal effect of the instruments. | A federal “refinancing” label itself releases every old obligation or security. | Preserve the federal classification; any jurisdiction-specific release inquiry remains held. |
| B024 — Partial: old exemption/new coverage | A replacement must qualify for its own threshold exemption; former business credit has its own consumer-purpose replacement rule. C017, C019–C022; S005/S011/S018. | Relevant period, purpose, extension/commitment amount, security, other exemptions. | The original exemption automatically follows every replacement. | Apply comment 3(b)-5.ii or 3(a)-6, as appropriate, using the legally relevant period. |
| B025 — Partial: consummation/disclosure timing | Ordinary timing is before legally determined consummation; only specific routes permit different timing. C023, C063–C070; S004/S007/S019. | Contractual obligation point, delivery route, estimates, later changes. | Application, approval, funding, signature, or first payment universally supplies the deadline. | Review §2(a)(13), §17(b), and only the applicable timing exception. |
| B026 — Partial: new agreement/other-law overlays | A complete new applicable disclosure set does not determine enforceability, authorization of charges, qualification, affordability, or compliance with every other product law. C062–C075; S001/S007/S008/S013. | All contractual and product-specific facts. | Disclosure compliance equals valid terms, approval, or a consumer right to refinancing. | Identify the exact separate public-law framework, retaining the parent holds until separately authorized. |
| B027 — Unresolved interval: version/effective period | Current bodies and the identified final issuances support the stated rules through their recorded cutoffs. They do not exhaustively clear the remaining interval or establish a future threshold. C001–C008; S001/S010–S018. | Official material after compilation cutoffs; any relevant future-effective issuance. | A crawl date, current banner, negative search, or old final rule proves unchanged law through all later dates. | Reopen the official current body and relevant final-publication material for the exact unresolved interval. |
Audit field · Evidence / analysis · Authority / read note · 60 data rows
| Audit field | Evidence / analysis | Authority / read note |
|---|---|---|
| Scope of proposed legal inquiry | ||
| Applicable regulatory instrument and version | ||
| Official source access date and time zone | ||
| Compilation cutoff and unresolved interval | ||
| Relevant effective or transition provision | ||
| Consumer-credit purpose classification | ||
| Natural-person / organizational / trust treatment | ||
| Creditor-definition predicates | ||
| Regular-extension measuring period and basis | ||
| Applicable actor exclusion or alternative regulatory route | ||
| Closed-end / open-end classification | ||
| Applicable exemption and measuring period | ||
| Existing obligation’s Subpart C coverage | ||
| Original-creditor / holder / servicer role | ||
| Successor-role legal basis | ||
| Same-consumer predicate | ||
| Governing-law question | ||
| Satisfaction or extinguishment predicate | ||
| Complete replacement predicate | ||
| Label and substantive legal effect | ||
| Existing obligation remaining open | ||
| New-creditor transaction boundary | ||
| Single-payment structure | ||
| Original terms and proposed changes | ||
| Renewal sequence and relevant prior disclosures | ||
| Variable-rate feature and index treatment | ||
| APR-reduction exception predicates | ||
| Remaining payment schedule comparison | ||
| Court-proceeding connection | ||
| Default or delinquency predicate and causal connection | ||
| Existing and revised APR classification | ||
| Unpaid-balance components | ||
| Earned unpaid finance charge | ||
| Unearned prior finance charge | ||
| Rebate treatment | ||
| Credit against prior obligation | ||
| New cash and payments on consumer’s behalf | ||
| Financed non-finance-charge costs | ||
| New finance charges | ||
| Prepaid finance charges | ||
| Amount-financed calculation method | ||
| Duplicate-inclusion or duplicate-subtraction check | ||
| Workout amount-financed comparison | ||
| Insurance type, optional status, and renewal status | ||
| Initial insurance disclosures and affirmative request | ||
| Continuation-premium treatment | ||
| Existing and revised security requirements | ||
| Separate lien / obligor / guarantor release question | ||
| Applicable disclosure-content route | ||
| Consummation predicate | ||
| Delivery, retainability, and electronic-form conditions | ||
| Disclosure timing and exception predicates | ||
| Estimate and early-change treatment | ||
| Applicable disclosure recipients | ||
| Separate product-specific framework | ||
| Missing evidence and adverse inference to avoid | ||
| Next permissible generic public-law inquiry | ||
| Remaining parent holds | ||
| Researcher self-check | ||
| Independent review status |
Requested question / material subquestion · Status · Findings, claims, sources, examples, branches · 42 data rows
| Requested question / material subquestion | Status | Findings, claims, sources, examples, branches | Missing evidence or held limit | Exact permissible next inquiry |
|---|---|---|---|---|
| 1 — Complete current §20(a) | Answered, with temporal limit | C001, C024–C048; S001; comparison table | Post-October-26 compilation interval not exhaustively cleared | Official current body and final publications for that interval |
| 1 — Complete general and exception commentary | Answered | C025–C054; S001; E001–E006 | Full other §20 commentary not claimed | None needed for the selected text; use another subsection only if separately relevant |
| 1 — Old covered obligation; satisfaction; replacement; same consumer | Answered generically / application unresolved | C024–C027; B003–B004 | All contractual and identity predicates held | Comment 20(a)-1 and §2 definitions; governing-law question remains held |
| 1 — Original creditor, holder, servicer, successor | Answered generically / application unresolved | C014, C028–C029; B002, B006 | Role and succession facts absent | Compare the specific coverage language; do not import §23’s role definition |
| 1 — Labels versus legal effect | Answered | C025–C027; E001; B005, B008 | Actual legal effect absent | The precise federal test and, only if authorized later, relevant general contract law |
| 1 — Different creditor/new transaction | Answered | C029, C062–C065; B006 | New actor/coverage/disclosure route unknown | §§1–3 and applicable new-transaction provisions |
| 1 — No automatic obligor/lien release or savings | Answered as a limit | C074–C076; B022–B023 | Contract, security, cost facts absent | Separate generic release or cost framework only after parent hold |
| 2 — Consumer credit and purpose definitions | Answered | C009–C012, C016–C017; S003–S005/S010; B001 | Purpose facts held | Applicable §2/§3 purpose provision |
| 2 — Closed-end/open-end boundary | Answered | C013, C077; B020 | Plan facts held | §2(a)(20); separate transfer/conversion framework held |
| 2 — Creditor definition and regularity | Answered | C014–C015; S004/S010 | No actual actor classification; illustration-table rendering gap | Operative §2(a)(17), not an actor search |
| 2 — Actor exclusion | Answered as a boundary | C018; S003/S014/S018 | Alternative Part 226 framework not completed | General Board/CFPB allocation if relevant and separately authorized |
| 2 — Exemption framework and measuring base | Answered | C019–C022; S005/S011/S018; B024 | Product/security/period facts held; future threshold unverified | Exact §3 exemption and applicable annual rule |
| 2 — Consummation and contract/state-law dependence | Answered generically / application unresolved | C023; B004, B025 | Governing law and binding event absent | §2(a)(13) commentary; state-law inquiry held |
| 2 — New-disclosure legal basis and extent | Answered | C062–C073; S001/S007/S008/S013/S019 | Actual applicable route unknown | §18 or the identified specialized route |
| 2 — Old unearned finance charge | Answered | C053–C054; E004; B017–B018 | Earned/unearned and rebate/credit facts absent | Comment 20(a)-4 and §18(b) |
| 2 — No offer/approval/affordability entitlement | Answered as a limit | C075; B026 | Full substantive product laws held | Only a separately authorized applicable framework |
| 3 — Single-payment renewal | Answered | C035–C038; E005; B007–B009 | Original and renewal terms absent | §20(a)(1), comment -1, §17(c)(3) |
| 3 — APR reduction and schedule limits | Answered | C039–C041; B010, B013 | Remaining/revised schedules absent | Comments 20(a)(2)-1–2 |
| 3 — Court agreement | Answered | C042–C043; E006; B011 | Proceeding connection held; no case inquiry | §20(a)(3), comment 2(a)(14)-1.ii |
| 3 — Default/delinquency schedule or collateral change | Answered | C044–C047; B012–B015, B019 | Status, causation, APR, and amount components absent | Full §20(a)(4), not a generic hardship rule |
| 3 — Optional-insurance renewal | Answered | C048–C052; B016 | Optional status, renewal, initial disclosures absent | §20(a)(5) and relevant complete §4(d) branch |
| 3 — Rate-increase and additional-credit triggers | Answered | C041, C045–C046; B013–B014 | Correct APR and amount-financed inputs absent | §§4, 18, and §20(a)(4) comparison |
| 3 — Reasonable costs | Answered, narrowly bounded | C047, C057; S006/S009; B015 | No actual fee legality or rescission result | Keep §4(c)(7), §20(a)(4), and §23(f)(2) separate |
| 3 — Successive renewals and variable-rate considerations | Answered | C030–C038; E002–E003; B009 | Feature disclosures/index/renewal terms absent | Comment 20(a)-3; Part 253 only if separately necessary |
| 3 — Complete material official §20(a) examples | Answered | E001–E006, tied to C024–C054 | No actual application; unrelated historical numeric examples not adopted | None needed for the selected illustrations |
| 4 — Necessary timing provisions | Answered | C023, C065–C070; S007/S019; B025 | Actual route/consummation unknown | Exact §17 timing branch |
| 4 — Necessary disclosure-content provisions | Answered | C061–C064, C071–C073; S008/S013 | Product-specific applicability unknown | Applicable §18 categories; mortgage route held |
| 4 — Finance-charge/amount-financed distinction | Answered | C053–C061; S001/S004/S006/S008/S012/S013 | Component facts absent | Charge-by-charge public-law classification |
| 4 — Paid off versus still open | Answered as a distinction / application unresolved | C024–C029, C074, C077; B004, B020, B023 | Legal closure/replacement facts absent | General replacement and plan definitions |
| 4 — Existing debt/new money; principal/charges; arrears/cash | Answered | C046, C053–C061; B014, B017–B018 | Component allocation unknown | Comment 20(a)-4 and §18(b)/(c) |
| 4 — Changed/unchanged security and release | Answered as a distinction / application unresolved | C020, C044–C047, C074; B019, B023 | Security and contract facts absent | Separate coverage, disclosure, and release inquiries |
| 4 — Open-end transfers/cards/promotions | Excluded beyond boundary | C013, C077; B020 | Parent hold | Subparts B/G only in a separate authorized investigation |
| 4 — Assumptions/ARM/mortgage/rescission | Excluded beyond necessary cross-references | C034, C047, C063–C065; B021 | Parent hold; only §23(f)(2) comparison completed | Specific §19/§20(b)–(e)/§23 branch |
| 4 — High-cost/higher-priced loans; private education | Excluded beyond coverage pointers | C015, C019, C021, C063–C065 | Full §§32, 35, 46–48 frameworks held | Relevant product framework separately |
| 5 — Provision-specific comparison | Answered | Section 3; C027, C035–C052 | Actual applicability held | None required to complete the generic comparison |
| 5 — At least sixteen substantive branches | Answered | B001–B027, each with rule, evidence, missing facts, inference limit, next inquiry | Individual application unresolved/excluded as marked | Exact branch-specific public-law inquiry |
| 5 — Entirely blank worksheet | Answered | Section 5 | All entry fields deliberately blank | No factual entry or record query authorized |
| 6 — Optional symbolic reconciliation | Not supplied, with reason | Section 6; C053–C061 | Necessary component classifications absent | Resolve generic charge categories before any separately authorized model |
| 6 — Arithmetic versus regulatory classification | Answered | C053–C061; Section 6 | Arithmetic cannot establish legal character or authorization | Applicable finance-charge rule first |
| 6 — No unsupported amortization/savings forecast | Answered by exclusion | C076; B022; Section 6 | Timing, rate, term, fees, final payment, rounding absent | No forecast within this pass |
| Source method — versions, dates, read bounds, failures | Answered, with explicit gaps | Source register; C001–C008; Section 8 | Compilation intervals and listed access limits | Narrow official-source follow-up only |
| Review/acceptance boundary | Answered as a limit | Section 9 | No independent reviewer or acceptance action | Separate owner-controlled review |
Log item · What was actually done · Result and consequence · 8 data rows
| Log item | What was actually done | Result and consequence |
|---|---|---|
| L001 — Core rule | Opened current eCFR §20 and CFPB §20/commentary presentations. | Complete §20(a) and all its current commentary read. Other §20 frameworks were not represented as complete. |
| L002 — Definitions and exemptions | Opened the current §§1–3 bodies and material official commentary, then statutory definitions/exemptions. | Coverage gates and their conditional nature established; no actual entity or transaction classified. |
| L003 — Charges and disclosures | Read the selected complete material portions of §§4, 17, 18 and their interpretations. | Established the earned/unearned distinction, amount-financed method, and ordinary disclosure route with material exceptions. |
| L004 — Reasonable-cost distinction | Read §23(f)(2) and complete comment 23(f)-4. | Confined that calculation and successor rule to the rescission comparison; no full rescission conclusion. |
| L005 — Status and amendments | Read the identified 2011, 2021, 2022-correction, 2023, and 2026-threshold issuing materials. | Historical and operative provisions distinguished. Search results alone were not treated as authority. |
| L006 — PDF read limits | Read selected parsed text in S017 and S018 at the printed pages/indices recorded above. | No claim of whole-PDF visual reading, scanned-page inspection, form verification, or pixel review. |
| L007 — §22 recovery | A first retrieval was truncated; reopened the body and corresponding commentary. | Relevant §22(a)(1)–(3) and comments were then readable. No unresolved retrieval gap remains for C069’s narrow use. |
| L008 — Currentness checks | Examined current compilation notices, agency current-version bodies, and necessary final-publication materials. | Supports the recorded text and dates; does not establish exhaustive clearance after each compilation cutoff. |
Failure / limit · Complete URL or exact location · Treatment · 9 data rows
| Failure / limit | Complete URL or exact location | Treatment |
|---|---|---|
| F001 — Full eCFR Supplement I too large | https://www.ecfr.gov/current/title-12/chapter-X/part-1026/appendix-Supplement%20I%20to%20Part%201026 | Retrieval failed with a content-size error. The necessary commentary was read from section-specific CFPB presentations and relevant Federal Register material. This is an access failure, not evidence of absence. |
| F002 — Federal Reserve commentary mirror too large | https://www.federalreserve.gov/frrs/regulations/consumer-financial-protection-bureaus-official-staff-commentary-on-regulation-z.htm | Content-size error. No search snippet from this mirror supports a substantive claim or status conclusion. |
| F003 — Legacy OLRC granule links failed | https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1602&num=0&edition=prelim https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1603 | Failed legacy retrievals. Recovered using the official /us/usc/119-121/ sources in S010–S013. |
| F004 — OLRC title-query links inaccessible | https://uscode.house.gov/view.xhtml?req=title:15%20section:1602%20edition:prelim https://uscode.house.gov/view.xhtml?req=title:15%20section:1603%20edition:prelim https://uscode.house.gov/view.xhtml?req=title:15%20section:1638%20edition:prelim | Not used as evidence. The successful statutory snapshots and their actual currency notices control the register. |
| F005 — Batched output truncation | Selected definition/disclosure retrievals; initial §22 retrieval | Reopened the material portions individually. A truncated response was not counted as a complete read. |
| F006 — CFPB §3 parsing omission | S005, §3(h)(6) and following material | Recovered complete text from eCFR, including the disclosure election and paragraph (i). |
| F007 — Creditor illustration table not rendered | S004, numerical example table within creditor commentary | Not reconstructed or relied on. The operative numerical standards and readable counting commentary support C015. |
| F008 — Future threshold not verified | Official annual-threshold search and S018 | No 2027 threshold authority is certified. Lack of a retrieved future rule is not proof that none exists. |
| F009 — Incorporated frameworks not fully read | Part 253; Appendix J; E-SIGN; full §§19, 20(b)–(e), 23, 32, 35, 46–48; Board Part 226 | Specific held boundaries, not silent assumptions. The report states only the narrow cross-reference or distinction actually supported. |
Check · Result · 13 data rows
| Check | Result |
|---|---|
| Independent R035 foundation | Fresh R035 primary-source browsing used; R033 findings were not adopted. |
| Complete selected core | Entire §1026.20(a), every nested exception, all general comments, and every exception comment read. |
| Material exceptions preserved | Single-payment allowances, APR/schedule restrictions, court predicate, default/delinquency causation, APR and amount-financed limits, insurance renewal/initial disclosures, and variable-rate qualifications retained. |
| Different-creditor distinction | Original creditor/holder/servicer coverage separated from a new transaction by another person. |
| Prior-charge treatment | Unearned unrebated/uncredited charges separated from accrued unpaid charges; no automatic refund right inferred. |
| “Reasonable costs” distinction | Finance-charge exclusion, workout amount-financed test, and rescission calculation kept separate. |
| Quantitative claims | Limited to sourced legal thresholds, periods, counts, and tolerances, with their measuring bases and triggers; no fabricated transaction values. |
| Examples | Only material official generic §20(a) illustrations used; no actual or fictional account record created. |
| Worksheet | Evidence and authority entry fields remain blank. |
| Read limits | Selected versus whole reads, HTML versus parsed PDF, and inaccessible content expressly identified. |
| Source independence | Formats and sections of Regulation Z grouped as one instrument family, not independent corroboration. |
| Review status | This is the researcher’s self-check. No independent review, component acceptance, parent acceptance, operational acceptance, or publication acceptance is claimed. |
| Scope completion | The focused public-law investigation is delivered with its stated unresolved intervals and parent holds. It does not finish A035. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
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Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
Recorded check status: fresh selected primary body read with explicit bounds
The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
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Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
conditionally reviewed currentness evidence and application holds
Original saved Markdown SHA-256: 39a61ab0f8bef46a88091a04443b50988506471c4540ff2a2ca6663e5621cbc5. Public formatting, private-reference removal and correction annotations are separate from that immutable original.