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#2001919 - 03/16/15 08:50 PM Employee Referral Program
SunnyFL, CRCM Offline
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Joined: Sep 2004
Posts: 205
Do you have a program where you pay a fee to employees for making a referral for new accounts or loans? Is this a program that you monitor internally at your Bank or do you use a third-party vendor for this tracking, etc. Please send me a PM with info regarding the vendor if you prefer. Thanks much!

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General Discussion
#2003229 - 03/23/15 01:53 PM Re: Employee Referral Program SunnyFL, CRCM
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
I can't imagine outsourcing this tracking to a 3rd party vendor. IMO that would be the individual's manager's responsibility or the department manager whose department is receiving the referral.

You also want to review Reg. Z 1026.36 and its Commentary for the definition of a loan originator. You could inadvertently be making your employees loan originators.
The opinions expressed are mine and they are not to be taken as legal advice.

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#2003357 - 03/23/15 05:53 PM Re: Employee Referral Program SunnyFL, CRCM
osucpa Offline
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Joined: May 2011
Posts: 1,400
Agree with Dan, this is performed in house.

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