On February 26, 2020, the CFPB added ten new TRID FAQs to their website addressing the topic of lender credits. The new FAQs answer the following questions:

What is a lender credit for purposes of the TRID Rule?
What is the difference between a specific lender credit and a general lender credit?
Is a creditor required to disclose a closing cost and a related lender credit on the Loan Estimate if the creditor will absorb the cost?
Is a creditor required to disclose a closing cost and related lender credit on the Closing Disclosure if the creditor will absorb the cost?
How are lender credits disclosed on the Loan Estimate?
How are lender credits disclosed on the Closing Disclosure?
How does a creditor disclose lender credits for a loan that the creditor refers to as a “no-cost loan”?
How does a creditor disclose lender credits if the creditor provides a credit, rebate, or reimbursement to offset specific closing costs charged to the consumer?
How does a creditor disclose lender credits when it is offsetting a certain dollar amount of closing costs charged to the consumer without specifying which costs it is offsetting?
Can lender credits change?

The full CFPB FAQs can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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