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.

LOADING PDF: If there are any problems, click here to download the file.

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

Written by:


Lenders Compliance Group on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.