Loan Originator Compensation Policy Manual

The Consumer Financial Protection Bureau's Loan Origination Rules revisions amended Regulation Z of the Truth-in-Lending Act (TILA), and affected the loan origination process. Do you have your loan originator qualification and compensation policies in place? Don't worry - we can help.

Overview

The AllRegs Loan Originator Compensation Policy Manual is a comprehensive, turnkey policy manual that provides background and history of the law and explains permissible forms of compensation for lender-paid and consumer-paid options. It clarifies the CFPB's definition of loan originator, includes revisions for integrated disclosures, provides current rules for Loan Originator Qualifications and Anti-Steering and Safe Harbor, and includes supplementary material that may be incorporated into your Loan Officer Compensation agreements.

The Loan Originator Compensation policy manual is required for all mortgage originator organizations with employees compensated for originating loans. Implementation of a Loan Originator Compensation Policy Manual is required by the CFPB.

The policy includes the following topics:

  • Introduction
  • Accountability and Monitoring
  • Staff and Training
  • General Principles for Compliance
  • Loan Steering
  • Compensation Agreements


Benefits

The plan features the following benefits:

  • Complete AllRegs' Loan Origination Compensation Policy Manual saving you development time and resources
  • Your plan is delivered via email within one business day after purchase
  • Meet your regulatory or internal compliance requirements
  • Affordable one-time purchase fees

Optional Services

Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.

Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.

Contact your account manager for information regarding these optional services!


Policy Manual
Loan Originator Compensation
Section Title Priority Action
1.1 Goals and Objectives Mandatory Review Include the point of view or culture of your organization in this section, if applicable.
1.2 Required Review Mandatory Review Be sure this accurately reflects your company’s annual policy review process.
1.5 Disciplinary Action Mandatory Review This section includes disciplinary actions by senior management, and you should modify this to fit your organization’s requirements.
2.1 Internal Controls Mandatory Review Include or reference related procedures in this section.
2.2 Managerial Oversight Mandatory Review Review the requirement for an executive assigned to compliance with the final rule and identify by position title.
3 Staff and Training Mandatory Review Include the means by which your organization provides and tracks required training.
3.2 Ongoing Loan Originator Training Recommended Best Practice You may want to consider adding content to describe the training program that is in place for Loan Originators.
4.2 Integrated Disclosures and NMLS Optional Enhancement Consider including the NMLS ID for your organization in this section.
4.5 Loan Originator Qualification Rules Recommended Best Practice It is important to incorporate these rules into your business processes and indicate that here.
4.6 Overview of Compensation Rules Recommended Best Practice This section refers to Branch and Production Managers as executive or administrative positions that do not “arrange … extensions of credit”. If this is not the case in your organization, you should update this section.