TopMortgage Compliance Update (1)

April 3, 2013    


Loan Originator Compensation: New Rules

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On January 24, 2013, as the last of the Final Rules of the Consumer Financial Protection Bureau (CFPB) rolled out, I offered an outline of all of them, entitled "CFPB's Gang of Seven (Final Rules)".

I listed them in order of issuance, as follows:

1. Ability-to-Repay (ATR)
2. High-Cost Mortgage (HCM)
3. Escrow
4. Servicing
5. Appraisals for High-Risk Mortgages
6. Copies of Appraisals
7. Mortgage Loan Originator Compensation

Having come through the last two months responding to numerous questions about these Final Rules, I have been able to cobble together some of the most salient questions, regulatory features, and concerns that our clients have expressed about them. And when I have spoken to the media types, it seems that they also have a set of questions and interests that are not being fully addressed in the current dialogue. Of abiding interest is the change relating to loan originator compensation.

With that in mind, I want to provide a brief outline of some loan originator compensation issues, offering additional details garnered from two months in the trenches working through these regulatory issues on behalf of our clients. From time to time, I will have more to discuss about many regulatory changes anticipated in 2013 and 2014. I am going to conduct this review topic by topic, rather than just as specific regulations subject to a final rulemaking.

Best wishes!
Jonathan Foxx
President & Managing Director
Lenders Compliance Group
      • Terms and Conditions
      • Retirement Plans
      • Factors and Proxies
      • Dual Compensation
      • Non-loan Originations Services
      • Points and Fees
      • Loan Originator Qualifications
      • Mandatory Arbitration Clause
      • Single Premium Insurance
      • Record Retention Requirements  
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