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#2143748 - 08/25/17 05:55 PM Deposit bonus for LO's? (what?)
Darth HMDA, CRCM Offline
Diamond Poster

Registered: 12/13/13
Posts: 1199
Loc: CA
Question of the day...

Management wants to incentivize mortgage loan officers to bring in deposits. According to initial discussions, this will not be tied to loan in any way.

The LO will receive a percentage of deposits over a certain amount brought in by referring people to the deposit side.

It's not tied to loans... but is there an issue with this under the LO compensation rules?

TGIF...
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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Loan Originator Compensation Rule
#2143798 - 08/28/17 10:33 AM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
Darth HMDA, CRCM Offline
Diamond Poster

Registered: 12/13/13
Posts: 1199
Loc: CA
eh?
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2143922 - 08/28/17 04:56 PM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
Darth HMDA, CRCM Offline
Diamond Poster

Registered: 12/13/13
Posts: 1199
Loc: CA
bump - sorry I know its an unusual question in a forum not looked at all the time
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2143930 - 08/28/17 05:03 PM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
rlcarey Offline
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Registered: 07/16/01
Posts: 65058
Loc: Galveston, TX
Non-mortgage related compensation would just be a component of wages.
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#2143931 - 08/28/17 05:05 PM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
Kathleen B Offline


10K Club

Registered: 12/27/00
Posts: 21242
Well, it is not uncommon to want to develop a relationship vs just transactional business. Then you have a customer to whom you can sell other products. You actually can require a deposit account for a loan (the traditional banking product exemption) so merely trying to encourage customers to open an account should be fine.

I can't think of a problem with the "incentive" to the LO, but if I do will post back.
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Kathleen O. Blanchard, CRCM "Kaybee"
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#2143932 - 08/28/17 05:06 PM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
Kathleen B Offline


10K Club

Registered: 12/27/00
Posts: 21242
Randy posted while I rambled on. I have not been able to sign in for a while. Finally got it straightened out!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2144228 - 08/30/17 11:23 AM Re: Deposit bonus for LO's? (what?) [Re: Darth HMDA, CRCM ]
Darth HMDA, CRCM Offline
Diamond Poster

Registered: 12/13/13
Posts: 1199
Loc: CA
Thank you both. Didn't think it was an issue as not a proxy for the loans itself.. but wanted to double check.

Thank you very much smile
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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