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#2279647 - 01/10/23 06:45 PM L/O acting as both L/O and real estate agent
bean2 Offline
Member
Joined: Apr 2019
Posts: 76
Is it permissible for a Loan Originator to act as both the LO and the Real Estate Agent on the same transaction? Can the originator receive dual compensation? Or does reg. 1026.36(d)(2)(i)(B) prohibit this?

If the compensation comes from the originator's employer and a separate (non-affiliated) Real Estate Agency. For example, L/O is employed by ABC lending and also sells real estate for XYZ Realty. The L/O compensation is paid by ABC lending and the real estate commission is paid by XYZ realty to the L/O.

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Loan Originator Compensation Rule
#2279668 - 01/10/23 11:28 PM Re: L/O acting as both L/O and real estate agent bean2
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
This would be illegal in some states and involves a huge conflict of interest and no bank in their right mind would allow this to happen.

In every bank I have ever been involved with and faced a situation like this, the ultimatum was put down - pick your career and be a banker or get out.
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#2279694 - 01/11/23 03:25 PM Re: L/O acting as both L/O and real estate agent bean2
bean2 Offline
Member
Joined: Apr 2019
Posts: 76
I didn't think the regulation permitted this, but wasn't 100% sure. Thank you for your feedback.

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