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#2122748 - 03/20/17 04:50 PM Specific Lender Credits and APR
Griff0rd Offline
New Poster

Registered: 03/17/17
Posts: 4
I have a regulation question around specific lender credits and the APR. I have been looking today in regulation, but haven't been able to find the specific ruling on this:

Is it acceptable to exclude from the APR disclosed pre-paid finance charge items that we apply a specific line item lender credit to?

Example: If a bank applies $300 line item credit for processing fees, can it exclude the $300 from the APR?

Any help would greatly appreciated.

TRID - TILA/RESPA Integrated Disclosures Rule
#2122752 - 03/20/17 05:06 PM Re: Specific Lender Credits and APR [Re: Griff0rd]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 61920
Loc: Galveston, TX
Yes - because it can only be a finance charge if the borrower actually pays for it. This is compared to general lender credits, which cannot be used to impact the APR.
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