This is in regards to a TRID loan. We had a lender refund part of an origination fee after closing for a "good customer". Do we need to re-disclose the Closing Disclosure or because it was an event after closing we need to just document the reason for the refund (memo to file)?

Yikes! I don't think the CD is the issue at all. Make sure the term "good customer" is specifically defined in your loan policy and make sure other "good customers" get the same refund.

We had a lender refund part of an origination fee after closing for a "good customer".

Agree w/ swiggles - could be a fair lending issue unless defined and offered to similar circumstance customers.

I think this would require re-disclosure.

I agree.

Why on earth would a loan officer have authority to refund any fee without an exception approval?

I would be pulling this loan officer's files to see if they have made any such concessions to a protected class that has similar "good customer" characteristics.

Just the white males who make over the median income for the area.

Just the white males who make over the median income for the area.

I understand your comment .....but it does represent my concern...chances are this loan officer has not granted such a concession to a female or minority borrower with similar "good customer" characteristics....IOWs the bank is allowing a practice awaiting referral to the DOJ.

IMHO an individual loan officer should never have the authority to make pricing concessions. All such concessions should go through an approval process involving the appropriate committee and the loan officer presenting the concession should have no vote in the decision process.

Correct! And if your bank ever hits that rocky road towards the DOJ....even if it survives with no findings, you will NEVER want to travel that road again. I think it leads to Hades....honestly.