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#2195515 - 10/16/18 02:54 PM Disclose a Discount Rate vs Full Rate?
Andrew White Offline
New Poster
Joined: Feb 2016
Posts: 2
Currently, we have a program that provides a .25% discount rate for setting up automatic payments and a deposit relationship. We have a disclosure that is signed with the initial disclosures where the applicant indicates that the applicant will fulfill the criteria to obtain the rate discount. The LEs and CDs proceed with disclosing the discount rate and then a second disclosure and addendum to the note is signed at closing upon confirmation that all the conditions were met. If the applicant had not met the criteria for the discount by closing (which has never occurred), we planned on issuing a revised CD and waiting a new 3-day period prior to closing. Is this proper, or should we be disclosing the the non-discounted rate on the LE/CD (which I think is contrary to the regulation as the actual terms of the transaction expected by the applicant and lender would never be disclosed)?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2195573 - 10/16/18 06:44 PM Re: Disclose a Discount Rate vs Full Rate? Andrew White
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,668
Hey Andrew - It depends on when the agreement for the discount is executed. What you are doing sounds appropriate. The 3 day waiting period would depend on some other factors, but would likely play out like that. Be careful with these products because if they cancel the auto-pay feature and the rate goes back up by the .25%, then you have an Adjustable Rate Mortgage and all the disclosures that come with that.

This should be helpful for you: https://www.bankersonline.com/forum/ubbt...ure#Post2163862

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#2195603 - 10/16/18 09:32 PM Re: Disclose a Discount Rate vs Full Rate? Compliance NABW
Andrew White Offline
New Poster
Joined: Feb 2016
Posts: 2
Thank you.

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