We are offering a mortgage coupon valued at $500.00 but in the fine print of the advertisement, it states, "this offer is not available for loans where an appraisal is not required by the Bank". Can we document this as a general credit on the LE/CD or by saying an appraisal is required to receive the credit, does that turn it into a specific lender credit which has different disclosure requirements on the CD? We are questioning the stipulation that the appraisal be obtained in order to receive the credit and wondering if that is acceptable.

Not sure it makes it a specific credit - but I am curious as to what is the rationale? If your lower loan amounts do not require appraisals and your minority applicants usually apply for lower loan amounts, how does this not present fair lending issues?