Skip to content
BOL Conferences
Thread Options
#1532056 - 04/06/11 03:28 PM Loan Originator Compensation Rule
t0dd Offline
100 Club
Joined: Sep 2004
Posts: 229
We have 5 loan officers in which all but one are paid a salary. Commissions paid to the one loan officer is based on closed loan volume for the month. We offer ARM, FIXED and VA loans. All loans are funded in our name and the majority are sold to the secondary market. Should we have only our commission paid loan officer complete the Loan Option Presentation Acknowledgment form or all loan officers complete the form? I am having a real hard time getting my arms around this one.

Thanks

Return to Top
Lending Compliance
#1532088 - 04/06/11 03:58 PM Re: Loan Originator Compensation Rule t0dd
Sheldon Hendrix Offline
Diamond Poster
Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
You shouldn't have to concern yourself with steering if you are compliant with the loan compensation provisions (.36(d)(1)), and you are originating with your own funds. The steering issue is something that really only applies to brokers, or institutions who would fall under the broker definition.

Return to Top

Moderator:  Andy_Z