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#2156745 - 12/11/17 02:56 PM Mortgage Closing Coupon
TeeBee Offline
Member
Joined: Jun 2007
Posts: 68
New York
Our mortgage department wants to offer a coupon for $200 off closing costs when a borrower is pre-qualed for a mortgage. It would be offered on all mortgages, except for the ones that we broker out - VA and FHA. The hope is that we can retain more of the approved pre-quals and they will turn into applications. I am concerned about the fair lending implications of not offering the discount on VA and FHA - disparate impact. However, because of the broker arrangement, I am being told we really can't do anything - we don't collect any fees from these applicants, so there is nothing to waive. Thoughts?

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Fair Lending
#2156747 - 12/11/17 03:02 PM Re: Mortgage Closing Coupon TeeBee
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
So your bank doesn't make any money on VA or FHA loans?
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#2156752 - 12/11/17 03:17 PM Re: Mortgage Closing Coupon Skittles
TeeBee Offline
Member
Joined: Jun 2007
Posts: 68
New York
My thoughts exactly. I was told we could possibly refund them something after closing.

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#2156769 - 12/11/17 04:41 PM Re: Mortgage Closing Coupon TeeBee
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
TB, the bank would be providing a coupon to all those that it prequalified, not those that it took an application from.
Since the bank brokers out the government insured loans, it cannot prequalify those loans - another institution is making that decision.

I see no issue, unless the bank is steering people into the VA/FHA programs.
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