residential loan refinance to get a lower interest rate

Interest rates may come down at some point.  I've got a participant who is asking if they take a residential plan loan now for 20 years and the rates drop over the next two years, can they refinance the remaining unpaid balance at the lower rate?  The plan does allow refinancing.

I've seen several discussions here and have reviewed 1/72(p)-1.  It seems like this is not well-defined.  I mainly wonder if since there is no acquisition at the time of the refinance, is it limited to five years at that point?

Thanks.

From the regs. Refinancing does not qualify as a principal residence loan. Prior Q&A also states requirement that loan is used to acquire the principal residence.

Q–8: Can a refinancing qualify as a principal residence plan loan?

A–8: (a) Refinancings. In general, no, a refinancing cannot qualify as a principal residence plan loan. However, a loan from a qualified employer plan used to repay a loan from a third party will qualify as a principal residence plan loan if the plan loan qualifies as a principal residence plan loan without regard to the loan from the third party.

(b) Example. The following example illustrates the rules in paragraph (a) of this Q&A–8 and is based upon the assumptions described in the introductory text of this section:

Thanks!