I was hoping someone could point me to resources that discuss clawback of MLO compensation. Thank you in advance for any assistance you can provide. I am not finding much.

See 36(d)(1) Payments Based on a Term of a Transaction

Comment 2(i)(G)

So are you saying that because that's a permissible method of compensation, it can also be the source for a clawback on compensation if there are issues with quality?

And on a side question, clawbacks would need to come from future compensation across all compensation and not be pulled from a single or past transaction?

Additional examples can be found in .36(d)(1) - Comment 7.

How you assess any compensation reduction is an HR issue and not one for compliance.

Thank you again!