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#2245668 - 11/18/20 09:12 PM Salaried LO- incentive bonus
WABComply Offline
100 Club
Joined: Jul 2017
Posts: 229
Its been awhile since I needed to go over this but now I am back and kind of lost. Currently our LOs are salaried and we are a retail/portfolio Bank.. Nothing is paid directly from the consumer or the Bank per loan to the LO and LOs have no say as to pricing. Due to COVID and a slow down in lending, the Bank is looking at offering incentive bonuses to our LOs for closed loan production. No terms will be permitted to be a part of the incentive plan, simply closing a loan is all that they need.

Where I get lost is this type of compensation is permitted, I believe we can offer bonus as part of tax incentive plan (401K) but can a loan officer in this case be directly compensated by the Bank up to 10%,. There is no lo compensation plan that includes bonus so would one have to be drawn up or would this general incentive plan be permitted,

Sorry, like I said, its been a while since I needed to revisit this part of TILA.

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Loan Originator Compensation Rule
#2245707 - 11/19/20 07:49 PM Re: Salaried LO- incentive bonus WABComply
WABComply Offline
100 Club
Joined: Jul 2017
Posts: 229
I feel that we may provide such bonus as a non-deferred profits based plan. Any thoughts?

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