Posted By: SunnyFL, CRCM
Employee Referral Program - 03/16/15 08:50 PM
Do you have a program where you pay a fee to employees for making a referral for new accounts or loans? Is this a program that you monitor internally at your Bank or do you use a third-party vendor for this tracking, etc. Please send me a PM with info regarding the vendor if you prefer. Thanks much!
Posted By: Dan Persfull
Re: Employee Referral Program - 03/23/15 01:53 PM
I can't imagine outsourcing this tracking to a 3rd party vendor. IMO that would be the individual's manager's responsibility or the department manager whose department is receiving the referral.
You also want to review Reg. Z 1026.36 and its Commentary for the definition of a loan originator. You could inadvertently be making your employees loan originators.
Posted By: osucpa
Re: Employee Referral Program - 03/23/15 05:53 PM
Agree with Dan, this is performed in house.