Symptom
The Lender-Paid Compensation to Broker value does not print on page 2 of the Loan Estimate.
Cause
Indirect lender compensation to the loan originator is disclosed on only the Closing Disclosure.
Per CFPB 1026.37(f), commentary (2)
Indirect compensation from the lender to the originator is not disclosed on the Loan Estimate, but rather is disclosed on the Closing Disclosure. However, direct compensation to the loan originator from the borrower is disclosed on the Loan Estimate.
- When the Include Lender-Paid Compensation to Broker check box in section A, Origination Charges, on the Fees Worksheet or Closing Costs Worksheet is not selected, the Lender Paid Compensation to Broker is not disclosed on the Loan Estimate.
- When the Include Lender-Paid Compensation to Broker check box in section A, Origination Charges, on the Fees Worksheet or Closing Costs Worksheet is selected, the Lender Paid Compensation to Broker is not disclosed on the Loan Estimate.
Resolution
The Lender-Paid Compensation to Broker field on the Fees Worksheet is compensation to the broker for the borrower interest rate credit. Therefore, it is considered indirect lender compensation and is not disclosed on Loan Estimate.
If any loan originator compensation is directly from the borrower but is not a borrower interest rate credit or indirectly from the lender, enter the originator compensation anywhere in the Origination Charges section on the Fees Worksheet.
