I don’t believe the bonus from the credit life is based on terms or conditions of the loan and I don’t think it is a proxy because it wouldn’t meet the two prong test:
1. The factor consistently varies with a transaction term or terms over a significant number of transactions.
2. The loan originator has the ability, directly or indirectly, to add, drop, or change the factor when originating the transaction.
Therefore, with the information you’ve given, I think it would be fine to pay the bonus you described.