FORUM PROFILE

Re: Loan Originator Compensation

Home Forums Truth in Lending/ Regulation Z Loan Originator Compensation Re: Loan Originator Compensation

#2662
jholzknecht
Keymaster

Section 226.36(d)(1) prohibits a person from compensating a loan originator, directly or indirectly, based on the terms of the transaction. Pay based on the overall profitability of the mortgage loan department appears to be compensation based indirectly on the terms of the loan. So the question is – Do the management employees receiving the bonus fit the definition of “loan originator?”