We have drafted a FAQs Outline exclusively for our clients.
The FAQs Outline consists of 90 questions and answers (22 pages) and comprehensively covers the Final Rule on Loan Originator Compensation.
We strongly recommend that you meet immediately with your residential mortgage compliance professional to review the forthcoming TILA requirements with respect to loan originator compensation. It will take some time to understand the requirements, revise programs, consider effects on your origination platforms, and revise your compensation plans and employment agreements.
In addition to drafting appropriate policies and procedures, revising compensation plans and agreements with loan originators and affiliates, we suggest that you also work through an actual FAQs type of outline in order to clarify and establish important issues.
Effective Date: April 1, 2011
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