A fairly recent DOL ruling states that Loan Officers are not exempt. See http://www.dol.gov/WHD/opinion/adminIntrprtn/FLSA/2010/FLSAAI2010_1.pdf.

This means that we must keep track of their hours and pay them overtime. When I waited tables, my minimum wage was way below the standard minimum wage because it was understood that I collected tips (around $2.75/hour). (1) Is anyone else familiar with tiered minimum wage? (2) Is it possible to pay a lower base minimum wage to loan officers, since it's understood they will make a commission.

Well, my hunch is the lower minimum wage only applies to "tipped" employees. So, that likely wouldn't apply to commission.

http://www.state.il.us/agency/idol/News/pdfs/mw.pdf