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#1124630 - 02/06/09 03:52 PM Originator compensation
diputs
Unregistered

Where would one look to find the (Dos & Don'ts) for lender compensation in RESPA?

We want to make sure that our lenders (MTG Originators) compensation is in line with RESPA especially as it may related to interest rates.

Where do we start?

Thank you

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Lending Compliance
#1125705 - 02/08/09 09:52 PM Re: Originator compensation
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,941
Galveston, TX
If these are employees, there is no guidance in RESPA.
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#1125816 - 02/09/09 02:41 PM Re: Originator compensation rlcarey
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
As Randy states, you won't find any real guidance...I can say, however, that the regulators are looking at this. Paying commission on anything other than actual origination fee (IOW, paying comm on YSP, is being considered/frowned upon/investigated in regard to fair lending. If you do compensate based on total fees, including any YSP's, you will need to do more due deligence to attempt to make sure you don't see any disparate treatment regarding steering of rates for fees.
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My opinion only. Not legal advice.

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