Loan Originator Compensation: Past is Prologue - Part I

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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.

ARTICLE HIGHLIGHTS

-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

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