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Did the CFPB update the TRID rule FAQs about when a bank may reduce lender credits previously disclosed to a customer on a Loan Estimate?

Did the Consumer Financial Protection Bureau (Bureau) update the TRID rule FAQs about the circumstances under which a bank may reduce lender credits previously disclosed to a customer on a Loan Estimate?

Yes, the Bureau provided further clarity with a new FAQ on February 26, 2020. It appears that lender credits may be reduced but only in certain circumstances.

Specifically, it explains that lender credits may decrease only if there is an accompanying “valid changed circumstance or other triggering event,” and the bank provides the consumer with a revised estimate within three business days of receiving information sufficient to establish that the changed circumstance or other triggering event has occurred.

If lender credits have decreased, detailed documentation is important as a decrease in the amount of the lender credits disclosed on the Loan Estimate can lead to a tolerance violation of the good faith standard.

See more from the CFPB

(April 2020)

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