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#2162708 - 02/01/18 02:50 PM re Marketing lender credit
Mike T Offline
Member
Joined: Dec 2016
Posts: 74
One of my loan officer is requesting if he can create marketing flyers to target market real estate agents.
He wants to market 1% lender credit of the loan amount to the buyers to grab the attention of the real estate agents.
Is this prohibited? Will this be a form of steering?
If not, what steps can he take to ensure we are compliant, re marketing flyer??
Last edited by Mike T; 02/01/18 03:29 PM.
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Marketing
#2162814 - 02/01/18 09:24 PM Re: re Marketing lender credit Mike T
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
No problem on the surface, but what buyers are going to actually get the 1% credit? Just those that go through that select broker? Sounds like you need to look at this from a fair lending perspective and not RESPA.
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#2162841 - 02/02/18 12:04 AM Re: re Marketing lender credit Mike T
Mike T Offline
Member
Joined: Dec 2016
Posts: 74
The buyers are going to get the 1% credit. I'll try to dig more and see if I can come up with any possible issues per Fair Lending.
thanks Randy.

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#2162960 - 02/02/18 06:13 PM Re: re Marketing lender credit Mike T
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
Fair lending agreed. Especially when your costs on a 50k loan and a 400k loan don't vary much, but the residual cost to the borrower will.

Also consider what will your credit cover: will they get the 1% even if it exceeds the costs? up to and only costs incurred? everything but prepaids? Be very clear otherwise you have UDAAP creep too.
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#2163046 - 02/02/18 10:30 PM Re: re Marketing lender credit Mike T
Mike T Offline
Member
Joined: Dec 2016
Posts: 74
I will tell the loan officer no due to fair lending. Thanks.

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