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#1788983 - 02/25/13 08:39 PM LO Compensation in Points and Fee Test
Still Smiling Offline
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Joined: Nov 2007
Posts: 767
If a bank pays their loan officers part of the fee retained by the bank would this have to be included in the points and fees? If so, wouldn't there be a duplication?
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#1791629 - 03/05/13 08:41 PM Re: LO Compensation in Points and Fee Test Still Smiling
okcowgirl Offline
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Joined: Aug 2010
Posts: 102
Oklahoma
I am hoping someone can shed some light on the points and fees pertaining to compensation in 1026.32(b)(1)(ii). This was covered some in the Lending Compliance conference but I am still confused. A comment was made that if it is straigt salary - no issue. If complensation - have issue.

Would someone please expand on this since it says "all" compensation.

"(ii) All compensation paid directly or indirectly by a consumer or creditor to a loan originator, as defined in 1026.36(a)(1), that can be attributed to that transaction at the time the interest rate is set"

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#1792539 - 03/07/13 09:01 PM Re: LO Compensation in Points and Fee Test okcowgirl
ccman Offline
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Joined: Sep 2007
Posts: 900
Same here. Our MLO is asking, "Does this include the sale to Fannie when the loan is sold?".

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#1805654 - 04/17/13 06:07 PM Re: LO Compensation in Points and Fee Test Still Smiling
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
Salary isn't included. I would have to find that section. But the CFPB is going to determine whether the actual hours can be tied to that transaction, and then it could possibly be included in the points and fees.
Clear as mud.

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#1805665 - 04/17/13 06:17 PM Re: LO Compensation in Points and Fee Test Still Smiling
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
Page 173 states "The base salary of a loan originator is also excluded..." The next sentence talks about consideration of the hourly wages.

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