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#2196273 - 10/24/18 03:44 AM LLPA's and Rebate Pricing
Katherine Offline
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Posts: 62
In disclosing LLPA's and rebate pricing, we net the LLPA's with the rebate pricing to disclose in Section A. the charges the consumer will pay and as such we do not disclose negative points. For example, if there is rebate pricing and LLPA's, we would net the amount and if the amount is a positive number, that number would be disclosed as an LLPA. If the amount comes out to a negative, then we would not disclose a negative number, but would instead disclose that negative figure as a lender credit. Is this what everyone else is doing?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2248862 - 02/08/21 06:06 PM Re: LLPA's and Rebate Pricing Katherine
RR Joker Offline
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Bringing this subject back up.

DEBATE:

When a borrower requests a higher rate in order to receive the YSP, is this shown as negative points or as a lender credit. To me, it's negative points and other larger institutions have apparently taken this stance [at least at some point, if not currently] and shown as a negative number in the discount point section, as that's what they directly relate to....pricing.

OR, since there seems to be no discussion of negative amounts shown in A, do they show as a lender credit?

I'm not a fan of the second option as it doesn't spell out as clear of a picture to me, but I haven't found any real good direction on it.
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#2248868 - 02/08/21 07:12 PM Re: LLPA's and Rebate Pricing Katherine
rlcarey Online
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A credit for selecting a high interest rate results in a General Lender credit. There is no such thing as negative points.

Read the lender credit section in the CFPB TRID FAQs: https://www.consumerfinance.gov/com...tegrated-disclosure-faqs/#lender-credits
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#2248936 - 02/09/21 08:16 PM Re: LLPA's and Rebate Pricing Katherine
RR Joker Offline
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Thank you so much, Randy for the cite.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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