Question:  We want to encourage more mortgage lending.  We would like to have an ad campaign with customers receiving a coupon for money towards closing costs.  How do we disclose this?

 

Answer:  According to a HUD FAQ, it must be shown on lines 204-209 of the HUD-1, reflecting "items paid by or on behalf of the borrower."  There is no Reg Z disclosure for this "bonus."  However, if it is $600 or more, then you need to give the customer a 1099.