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?