I misstated my original question. Does anyone have Loan Originators who only originate HELOCs? Do you include them in any type of bonus or incentive plan at your bank?

Any feedback would be appreciated. Thanks.

I know that REG Z and the Loan Originator Compensation rule does not apply to HELOCs

It doesn't?? News to me.

Is it correct for open-ended reverse mortgages the LO can be paid a percentage of the final broker check (for example, if the total wire we get is $12,000, we could pay the LO 35% of this). For close-ended reverse mtgs, the compensation plan would follow Dodd Frank rules (for example, 125 bps on all reverse, no matter the spread).

Open-end credit is not subject to the lender compensation rules, if that is what you are asking. However, some people think that there is really a limited window for when reverse mortgages make any actual financial sense to a borrower (regardless of the "trusted" personalities that hype them on TV) and you need to make sure you are not promoting predatory practices.