Pricing Disparity

Compliance – Lender Credit Incentives: Is it okay for a lender to offer a $500 credit to borrower, and/or also pay for appraisal?

Answer: A lender can pay for borrower’s closing costs/prepaids, and an appraisal would be considered a closing cost. The issue is not whether a lender can do this, it is whether or not it results in varying treatment of your clients. During an audit, regulatory bodies such as the CFPB will look to see if you [...]

2019-01-25T08:26:53-05:00January 25th, 2019|

Has Fair Lending Been Neutered?

By: Tammy Butler, Master CMB Fair Lending Perspectives-The CFPB’s Latest Decision If you have anything to do with Fair Lending in your company, you have no doubt heard the news about the recent change at the CFPB with regard to Mulvaney’s decision to strip the Fair Lending Office of enforcement duties and move those duties [...]

2018-06-01T13:09:18-05:00February 8th, 2018|