A lender under disclosed total finance charges by $750 on the Final CD signed at closing. If the lender disclosed a general lender credit equal to or greater than $750 on the CD signed at closing, can the lender issue a PCCD that reduces the general lender credit by $750 and reallocates that $750 towards fee-specific lender credits against fees that are finance charges so the total finance charges disclosed at closing will be accurate?

Welcome to BOL.

No - because a general lender credit is a 0% tolerance item, so it could not be lowered in that manner. A general lender or seller credit can never be used to offset finance charges.

I agree that lender credits are a 0% tolerance fee, but item 6 in the CFPB's Official Commentary under 1026.19(e)(3)(i) talks about aggregating specific and non-specific (general) lender credits when determining good faith (see below).

6. Good faith analysis for lender credits. For purposes of conducting the good faith analysis required under § 1026.19(e)(3)(i) for lender credits, the total amount of lender credits, whether specific or non-specific, actually provided to the consumer is compared to the amount of the “lender credits” identified in § 1026.37(g)(6)(ii). The total amount of lender credits actually provided to the consumer is determined by aggregating the amount of the “lender credits” identified in § 1026.38(h)(3) with the amounts paid by the creditor that are attributable to a specific loan cost or other cost, disclosed pursuant to § 1026.38(f) and (g).

If the lender allocates the appropriate aggregate credit, it shouldn't matter how the lender credit is allocated between general and fee-specific credits. Given that, is there any requirement that would prevent the lender from changing the general and fee specific allocation of lender credits post-closing as long as the aggregate lender credit is still disclosed in good faith?

I agree they are aggregated for disclosure purposes on the LE - but you cannot switch the nature of the credits during the transaction between the two categories of general and specific lender credits.

Sounds like someone is just trying to cover up their error rather paying for it.