NAILTA Supports Goliath (Loan Originator Compensation)


Rarely is there a significant controversy surrounding a government agency's work, especially where litigation is involved, when nearly all industry groups array on one side and the agency is alone to fend for itself on the other side. The FRB has now received support for its promulgating and interpretation of the TILA Loan Originator Compensation rule (Rule) from an important industry organization, with respect to the Rule as it relates to affiliate compensation.

In its letter of March 17, 2011, the National Association of Independent Land Title Agents (NAILTA), an organization representing independent title insurance agents and independent real estate settlement professionals, came out in support of the FRB's definition of the term "affiliate" as a "single person" for the purposes of the Rule.

Let's now consider NAILTA's point of view, as expressed in its letter (NAILTA Letter).

Article Highlights:


>Dual Compensation: A Syllogism

>NAILTA Sees Things Otherwise

>One-Stop Shop

>NAILTA Takes A Stand

>Is "Single Person" Correctly Construed?

Article provides links to text and resources.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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