Bonus Paid on Loan Account

Posted By: Banker Chick

Bonus Paid on Loan Account - 09/27/12 07:04 PM

Marketing is considering paying a Bonus to consumer customers on RESPA covered loans if approved. The bonus would not exceed $200 and be paid in the form of a VISA gift card. I don't believe that this violates section 8 rules and is allowed to be paid. Should it be reflected in the settlement statement and are there any reg Z considerations that should be made? If it must be reflected on the settlement statement, how?
Any insight into what is required is helpful! Thanks
Posted By: buggs

Re: Bonus Paid on Loan Account - 09/27/12 07:22 PM

Wouldn't be easier to give a credit towards closing costs?
Posted By: Banker Chick

Re: Bonus Paid on Loan Account - 09/27/12 07:26 PM

I would think so but marketing would rather do the gift card. Any thoughts on this method to make it work?
Posted By: Richard Insley

Re: Bonus Paid on Loan Account - 09/28/12 12:26 AM

Section 8's not an issue. It's always OK to give something to the borrower.

See the OSC to Section 1026.18(b) for Reg. Z's rule on payments of this type.
Posted By: buggs

Re: Bonus Paid on Loan Account - 09/28/12 07:22 PM

I have not dug into the regulation, but it would seem to me the safest thing would be to show the price of the card as a credit to the borrower somewhere on the settlement statement.