|
|
Loan Originator Compensation:
Past is Prologue - Part I |
|
|
|
|
|
Greetings!
You may be interested in reading my magazine article: 
Loan Originator Compensation:
Past is Prologue - Part I
It is published in the National Mortgage Professional Magazine.
(October 2012) Free Subscription to our Clients and Subscribers.
I have provided excerpts from the article and the download link. In this article, the first in a two-part series, I will consider the recent CFPB proposal, issued on August 17, 2012, which contains certain proposed rules governing mortgage loan originations, especially relating to the MLO compensation guidelines in Regulation Z, the implementing regulation of TILA. Comments for this proposal are due by October 16, 2012.I hope you enjoy this article. Please feel free to contact us at any time.
Regards,
Jonathan Foxx
President and Managing Director |
|
|
Excerpt
Small Business Panel
The CFPB is required to certify that a proposed rule will not have a significant, adverse, economic impact on a substantial number of small entities. The Small Business Regulatory Enforcement Fairness Act (SBREFA) provides the basis for a review, inasmuch as, among other things, "small businesses bear a disproportionate share of regulatory costs and burdens."
In order to comply with this requirement, the CFPB convened and chaired a Small Business Review Panel to consider the impact of the proposal and obtain feedback from representatives of the small entities that would be subject to the rule. When preparing the proposed rule and an initial regulatory flexibility analysis, the CFPB is expected to consider this panel's findings.
| BACK
|
|
Excerpt
Salient Topics
Here are certain, salient topics that were reviewed by the panel:
- Payment of Discount Points
- Payment of Origination Points and Fees in Creditor-Paid Compensation
- Payment of Origination Points and Fees in Brokerage-Paid Compensation
- MLO Retirement Plans, Profit-Sharing, and Bonuses
- Pricing Concessions and Point Banks
- MLO Qualification and Training Requirements
Let us now consider the panel's suggestions, concerns, resolutions, and recommendations.
| BACK
|
|
|
|
|
|
|
|
LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the United States specializing exclusively in outsourced mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks. We are pioneers in outsourcing solutions for residential mortgage compliance. We offer our clients real-world, practical solutions to mortgage compliance issues, with an emphasis focused on operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management.
This newsletter is free to subscribers, clients, and colleagues, who also regularly receive our free Mortgage Compliance Updates, Compliance ALERTS, and Commentaries.
Information contained in this email is not intended to be and is not a source of legal advice. The views expressed are those of the contributing author, as well as news services and websites linked hereto, and do not necessarily reflect the views or policies of Lenders Compliance Group, any governmental agency, business entity, organization, or institution. Lenders Compliance Group makes no representations concerning and does not guarantee the source, originality, accuracy, completeness, or reliability of any statement, information, data, finding, interpretation, advice, opinion, or view presented herein.
� 2012 Lenders Compliance Group, Inc. All Rights Reserved.
| 167 West Hudson Street - Suite 200 | Long Beach | New York | 11561 | (516) 442-3456
|
|
|
