Page 118 of the preamble document makes reference to a non-producing manager who is receives compensation based on the origination of others. What about a producing manager?
Last edited by pacar; 02/09/13 05:17 PM.
Currently, our producing manager receives a fixed rate of compensation (basis points) based on his own origination volume, and another fixed rate of compensation (basis points again) for the origination volume of those he supervises. One lump-sum payment is made to the producing manager each month that includes compensation for his own activity, as well as his staff.
I've been searching through the preamble and comments, trying to determine if this is still an acceptable practice, but have been unable to find anything definitive. In the section talking about profit-sharing plans, it says that compensation based on the terms of multiple transactions of multiple individuals is not allowed unless expressly permitted. Is that solely related to true profit-sharing bonus plans? Or would it apply in this situation? Is this considered "pooled compensation"?
Any thoughts on this matter?