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Rich Moldenhauer
Flagship Bank Minnesota

 
 
Mortgage Loan Originator Compensation Plan
Contributed by:Other (Trust, Facilities, Physical Security)
Asset size: Bank with over $1b
Location: Midwest
Description: This compensation plan required a significant amount of analysis to provide a fair plan to the MLO and at the same time provide a profitable structure for our institution. This plan will have to be tailored to each specific institution as compensation amounts will vary as well as volume expectations. The structure is there which should allow for a nominal amount of time to make it fit for you. The level of compensation may need to be adjusted to fit your expected yield on loans originated.

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MORE PEER CONTRIBUTED DOCUMENTS:

18 Documents 30 Answers 12 Exam Watches 55 Vendor Reviews

Mortgage Loan Originator Compensation
Asset size: with under $250m
Description: Mortgage Loan Originator Compensation is the latest in a series of compliance challanges facing community banks. Faced with complex regulations and a distinct lack of guidance from the agencies, even the smallest of banks must review their compensation plans to determine if changes are needed. We have a simple program in place for our Secondary Market that has been reviewed by an attorney and deemed to be compliant based on the rather non-complex approach we have taken. This document is our formal statement of intent to comply, and outlines the basic compensation structure in place.
Regulation Z Loan Originator Compensation and Qualification Procedures
Asset size: with under $250m
Description: The procedures (in the form of a Compliance Advisory utilized by our Bank) include Regulation Z requirements for loan originator compensation and qualifications. It includes sections for Purpose, Applicability/Effective Date, Loan Originator Definition, Compensation Rules, Recordkeeping, Loan Originator Qualifications, Loan Document LO Identification, Mandatory Arbitration Clauses, Single-Premium Credit Insurance, and Resources link.
Ability to Repay & Bankruptcy Indicator Procedures.
Asset size: with under $250m
Description: Use in conjunction with the Ability to Repay and Bankruptcy Indicator Worksheet.


RELATED QUESTIONS AND ANSWERS:
Q
Employee Referral Program Procedures
Asked by: Manager,‚ Marketing
Asset size: Bank with
Location:MI

Looking for content - procedures for an employee referral program for referring to the mortgage and trust departments, for example. How do you handle what constitutes a referral, how it's tracked, and how it's compensated.
A
Answered by:VP, ‚ Retail Banking/Branch Operations
Asset size: Bank with between $250m - $500m
Location: WI

Referrals can only be made if they themselves cannot complete the request, such as taking...
Q
Mortgage Loan Originator Commission
Asked by: CEO,‚ CEO
Asset size: Bank with
Location:FL

We are looking into adding a commissioned based mortgage loan originator in 2013 and are looking for ways banks structure the commission for originators?
A
Answered by:VP, ‚ Compliance/BSA/Legal
Asset size: Bank with under $250m
Location: NE

Our plan is attached. We received a compliance rating of 1 during our recent FDIC Complia...


RELATED EXAM EXPERIENCES:
FDIC - Compliance | February 2014
exam experience posted by a Audit from member with between $250m - $500m in assets
Detailed questions on originator compensation, Reg. E ACH procedures
FDIC - Compliance | August 2011
exam experience posted by a Audit from member with under $250m in assets
EFT Error Resolution Rules
FDIC - Compliance | December 2011
exam experience posted by a VP‚ Compliance/BSA/Legal from member with under $250m in assets
What letters did we send to our customers regarding the Opt-In/Opt-Out.

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