In your mortgage area, are loan officers allowed overages or underages, and would anyone have guidance (or a policy) that could be shared?
Thank you

Bump!

Is there any guidance on caps or policies for underages/overages on mortgage commissions?

Thanks

We do not have such a policy here. When developing a policy, make sure you think about the potential for fair lending issues. Have you looked at the U.S. Justice Department case against Fleet Bank's mortgage operation from several years ago? Here is a link to where you can view the complaint and the settlement agreement. http://www.usdoj.gov/crt/housing/documents/casesummary.htm#fleet

You would also want to keep in mind the Interagency Fair Lending Examination Procedures. Here is a link to a section of the OTS Compliance Activities Handbook that contains these procedures. http://www.ots.treas.gov/docs/48685.pdf Look at page 10 of the PDF file for a discussion of pricing.

This is not exactly what you wanted but perhaps there is something here that may be helpful to you in developing your policy. Good luck!

Thank you for your help.