Our MLOs are paid salary, no commission. If the bank gives all employees a year end bonus is that a problem for the MLOs? Are we OK as long as no part of a bonus paid to MLOs is connected with their loan volume or money the bank made due to them making loans? It may be based on percentage of salary, years of service, total profits (not just loans)etc.

We are looking at revising our overall bonus structure and I need to know if we have to consider any of this. I've read several pages of CFPB and other comments and posts and just wondered if this really doesn't apply to us due to them being on salary.

Any help is appreciated.

Generally, such compensation is limited to 10% of total salary.