new promotion which is coming in over my dead body:
"if we can't close your loan within X days you will receive a $2000 credit against your closing costs!"

wow! so we close on day X+1.
how do i show the $2000 credit?
on the HUD and hopefully i don't generte the need for a new TIL.

From the Q&A:
The General Instructions indicate that if a charge has been shown on the GFE as payable by the borrower but at closing it is paid by another person, including by the loan originator in a loan other than a no-cost loan, the fee should be shown in the borrower‘s column on the HUD-1 and be offset by listing a credit to the borrower on lines 204-209 of the HUD-1.

That's the easy part.
The issue is that doing so will change the TIL and MDIA will kick in again.
burgess, lie down and play dead!

Every now and again you have to just answer the easy part and let someone else deliver the bad news!

But will it, really? If it's just a lump sum credit, how do you know which/what ppfc's the lender is actually paying? Wouldn't they have to be further itemized in order to not count the page 2 ppfc's in the borrower's column as such?

I'd agree with you if it was a smaller credit. In my world, $2k is going to pretty much cover ALL the ppfcs.

It would here too, and lower the loan amount to boot!

Put the credit in the 200 series and ignore it from a TIL perspective. This is one promotion that compliance should not step into the way of in any manner:

Commentary 18(b) Amount Financed

2. Rebates and loan premiums. In a loan transaction, the creditor may offer a premium in the form of cash or merchandise to prospective borrowers. Similarly, in a credit sale transaction, a seller's or manufacturer's rebate may be offered to prospective purchasers of the creditor's goods or services. At the creditor's option, these amounts may be either reflected in the Truth in Lending disclosures or disregarded in the disclosures. If the creditor chooses to reflect them in the §1026.18 disclosures, rather than disregard them, they may be taken into account in any manner as part of those disclosures.

Wow. I don't recall reading or hearing that before! So we can give a lender credit and leave the TIL as it stands with the credited amounts being counted as PPFCs?

ok...learned my lesson for today so I can go home now, right?