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#1621372 - 10/28/11 02:43 PM Reg Z LO Comp --- Originating Manager
pacar Offline
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Joined: Jul 2007
Posts: 320
I'm trying to figure out if this is a violation or not.

We have a mortgage LPO offsite. We also have a secondary market program in the branch. The LPO is managed by a non-originating manager who receives compensation based on the production of the LPO. The LPO Manager himself is managed by the Manager of the Secondary Market program. *This* manager does originate loans in the secondary market program (but not at the LPO). *This* manager is *also* compensated based on the production at the LPO.

Are these techinically different departments? Is this a violation?
Last edited by pacar; 10/28/11 02:45 PM.
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Lending Compliance
#1621526 - 10/28/11 04:39 PM Re: Reg Z LO Comp --- Originating Manager pacar
pacar Offline
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Joined: Jul 2007
Posts: 320
I've been going crazy trying to locate the section in the reg or the commentary that discusses the distinction between an originating manager and a non-originating manger to try to answer this. Was that maybe just covered in the FRB webinar on this topic, or am I just missing it?

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#1621994 - 10/31/11 01:52 PM Re: Reg Z LO Comp --- Originating Manager pacar
Ishmael Offline
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Joined: Feb 2011
Posts: 232
Pequod
I do know that it was covered in an FDIC webinar on 6/17/11 on Truth in Lending - Mortgage Loan Originator Compensation Rules. Also in the FRB's 3/17/11 webinar. I think the applicable Commentary section is 226.36(a)(4).

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#1622022 - 10/31/11 02:36 PM Re: Reg Z LO Comp --- Originating Manager Ishmael
NMB Offline
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Joined: Jun 2002
Posts: 255
Southeast Michigan
Here is the link to the FRB webcast. It was free and can be re-played.

Philadelphia FRB Outlook Live
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