In California, we are closing a Piggyback First and Second mortgage purchase transaction. On the second mortgage, because of low pricing there's a rebate and the question was whether the rebate can be transferred to the 1st mortgage. I am not sure whether my question is compliance related, because I didn't see anything in the State Specific Residential Mortgage Lending Guide addressing the issue and this issue fell into my lap because I am doing compliance on interim basis until my boss can find a qualified candidate. Please help! Thank you.

First, Piggyback Line is a registered Service Mark of Fremont Bank.

That being said, I’m not sure I understand the question. I presume you have a loan escrow opened with a Title Insurance Company, and, I would guess that it is 1 escrow for both the 1st and the 2nd. The 2nd apparently has “negative” closing costs generating a credit to the borrower(s). Depending on how you advertised the “rebate”, you may be able to apply this amount to closing costs on the 1st. Did you promise “cash-in-hand?”