Not sure if this is a TRID specific question, so please move if need be.

Just caught wind that in an effort to "promote" mortgage loans, the bank is kicking around the idea of offering applicants a $500 credit towards closing costs. Would this type of promotion have any UDAAP possibilities? Would we have to go back and credit any past applicants if the bank does this?

Thank you

As an update, the bank is wanting to offer an incentive of $250 or $500 off closing costs if application is submitted online. I don't think that helps the cause any.

IMO running a promotion is not a UDAAP issue (so long as everyone receives the discount you stated they would receive).

Why do they just want to provide the credit to online apps? That may be problematic. You're promotion would adversely affect borrowers who do not have/use the internet (LMI, Elderly, etc.). Just my opinion but I wouldn't recommend doing that.

If you run a promotion, everyone gets the deal.

I agree with Darth. Our shop runs occasional promos where we offer a set amount off closing costs within a specific time frame.

If you run this kind of promo in June, you just make it clear it applies to applications received from June 1 through June 30 and there's no need to go back and give credits to applicants entering the queue before or after those dates.