Dodd-Frank modification vs. refinance

[Jesse Sumner]

I am researching an issue with regards to a loan with a balloon payment that is maturing. I have been told that under Dodd-Frank if a note with a balloon payment is renewed with the exact same terms it previously had (i.e. maturity, interest, payments, etc.) before it matures, it is considered a modification and not a refinance. Under these circumstances, this “modification” would be excluded from the requirements of Dodd-Frank. However, I read a post from @Bill Gulley where he cautions that the Act would apply if a new security agreement is filed under any modifications and that the modification would need to be compliant with the Act.

Has anyone else looked at this issue or have an opinion?