Compliance – Lender Credits – If the borrower locks the rate, and then decides to lower the loan amount, can we lower the lender credit to the borrower?

Answer: The quick answer probably won’t make you happy. It is my opinion, based on information from the CFPB’s Small Entity Compliance Guide, that the lender credit cannot be changed even if there is a material change to the loan amount. Reference:  Question 7.13 on page 59 of the small entity compliance guide from the [...]