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#1784525 - 02/09/13 05:00 PM Producing Manager Compensation
pacar Offline
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Joined: Jul 2007
Posts: 320
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?

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?
Last edited by pacar; 02/09/13 05:17 PM.
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Loan Originator Compensation Rule
#1784581 - 02/11/13 01:35 PM Re: Producing Manager Compensation pacar
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
When you say loan origination volume, are you talking loan amount or x growth in dollar amount of loans? If so, then what you are doing is permissible.
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#1784591 - 02/11/13 01:52 PM Re: Producing Manager Compensation pacar
pacar Offline
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Joined: Jul 2007
Posts: 320
Yes. It's a fixed amount based on the dollar amount of the loan. It looks like in (d)(1)(ii) the amount of credit is still not considered a "term or condition" ... so it does sound like what we're doing still works.

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