Skip to content
BOL Conferences Top Gun 23
Thread Options
#2282596 - 03/23/23 08:57 PM Promotional Credit
K. Bloom Offline
Junior Member
Joined: Mar 2007
Posts: 36
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.

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2282599 - 03/23/23 09:05 PM Re: Promotional Credit K. Bloom
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 81,314
Galveston, TX
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?
The opinions expressed here should not be construed to be those of my employer:

Return to Top