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My bank issued a refund that increased the lender credits in the final Closing Disclosure. On the HMDA loan application register, does the bank report on the amount of the lender credits from the final Closing Disclosure or the lender credits as reflected in the revised Closing Disclosure?

If, due to an error in the final Closing Disclosure, the bank issued a refund that increased the lender credits, does the bank report on the HMDA loan application register the amount of the lender credits from the final Closing Disclosure or does it report the increased amount of the lender credits as reflected in the later revised Closing Disclosure?

It depends on when the refund and revised Closing Document are issued. As comment 3 to §1003.4(a)(20) of Regulation C explains, the bank only provides the corrected amount if the corrected disclosure was provided prior to the end of the reporting period in which closing occurred. This applies whether the bank is filing quarterly or only annually. For example, if the bank sent the refund and revised Closing Disclosure on or prior to Dec. 31, 2019, it reports the amount of lender credits on the revised Closing Disclosure. If the bank sent the refund and revised CD after Dec. 31, 2019—it reports the amount of lender credits on the final Closing Disclosure, that is, the one provided at consummation. (February 2020)

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