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How do we report lender credits under HMDA? For instance, if the number is a negative #, do we just report the figure..not that it is negative? Our software does not allow a negative #. I have seen negative and positive amounts here.
Regulation C (§1003.4(a)(20)) requires disclosure “For covered loans subject to the disclosure requirements in Regulation Z, 12 CFR 1026.19(f), the amount of lender credits, as disclosed pursuant to Regulation Z, 12 CFR 1026.38(h)(3).” §1026.38(h)3) requires disclosure of, “The amount of lender credits as a negative number, labeled “Lender Credits” and designated borrower-paid at closing, and if a refund is provided pursuant to §1026.19(f)(2)(v), a statement that this amount includes a credit for an amount that exceeds the limitations on increases in closing costs under §1026.19(e)(3), and the amount of such credit under §1026.19(f)(2)(v).” Credits are shown as a negative amount on the closing disclosure since they reduce an amount payable by the consumer. The negative numbers from the Closing Disclosure are shown as positive amounts on the HMDA LAR.
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