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#2239543 - 07/14/20 02:23 PM Intra-Bank Mortgage Referrals
Professional Noun Offline
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Joined: Jan 2016
Posts: 5
My bank has hundreds of Mortgage Loan Originators (LOs). We currently have a referral system whereby associates enter customer/prospect information into an internal portal and a "referral" is sent to an LO based on several factors (location, association with branch, etc.). The bank associate has no control over where the referral lands unless they are a licensed and registered LO. Associates are compensated for referrals that result in a mortgage loan.

Our mortgage group is interested in growing our contact-center based LO numbers. These LOs do not have offices and conduct essentially all work over the phone/online/email. The mortgage group has proposed either (a) funneling all internal referrals to the contact-center LO group or (b) only compensating internal referrals to the contact-center LO group from associates can choose where referrals land (i.e., licensed and registered LOs).

I cannot think of a legal/regulatory problem with either of these proposals, but I feel like I am missing something. Does anyone have any thoughts one way or the other?

Thanks!

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Loan Originator Compensation Rule
#2239662 - 07/16/20 01:01 PM Re: Intra-Bank Mortgage Referrals [Re: Professional Noun]
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 74,489
Galveston, TX
Is long as the referrers do not fall under the definition of a loan originator in 1026.36 and subjected to those limitations, it is purely an internal compensation plan.
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