FAQs Outline - Loan Originator Compensation Rule

LOAN ORIGINATOR COMPENSATION

450 Questions and Answers

146 Pages

Glossary

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Version 23 - April 10, 2012

Is there a “best practices” version of the anti-steering disclosure?
Are FHA and VA loans excluded from the anti-steering disclosure requirement?
What are five (5) questions that an originator should consider when completing the GFE?
What happens if the loan amount is too low to pay the compensation percentage?
How is pricing coordinated on a rate sheet?
Is the Yield Spread Premium (YSP) now defunct?
Does the compensation level stay the same if the borrower pays the fees or the lender pays?
On VA loans, is there a limit to 1% origination on brokered Lender Paid options?
May a correspondent still receive a Service Release Premium (SRP)?
What are the implications for compensation paid by affiliated creditors?
How is compensation treated for two affiliated loan originators?
Does the implementation of the Rule supersede other regulatory requirements?
How should a lender update its requirements to purchase correspondent loans?
Broadly speaking, what are the anti-steering prohibitions under the Rule?
Are salaried loan officers of non-profits subject to the Rule?
If a broker has multiple branches, what is an acceptable compensation plan with lenders?
May the closing costs be included in the loan amount in a refinance transaction?
Is the RESPA treatment of charges and credits disregarded in all respects under the Rule?
Is there a simple, decision-based flow chart for the Consumer Paid model?
Is there a simple, decision-based flow chart for the Lender Paid model?
What federal government agency handles violations of the Rule?
In the Consumer Paid model, using a rate sheet how are fees disclosed on the GFE?
In the Lender Paid model, using a rate sheet how are fees disclosed on the GFE?
May Box 1 of the GFE be decreased on a Consumer Paid transaction at closing?
How are the fees in Block 2 of the GFE applied?
May the compensation be greater for government loans than conventional loans?
Is there a chart that highlights similarities and differences between the two models?
What are six pricing scenarios for brokers?
How is each of the six pricing scenarios for brokers disclosed on the GFE?
Is there a chart that outlines fees permitted by the Lender Paid and Consumer Paid models?
How is the origination fee used by a broker to receive compensation?
What is the “salary” that must be paid to a loan officer employee?
How should overtime pay be calculated for loan officer employees?
What are the remedies for not paying overtime to a salaried loan officer employee?
What are the implications for the administrative exemption?
If a lender receives an application after it has been locked, what compensation plan applies?
Is it permissible to pay a flat fee plus a commission to a loan originator?
How is compensation on employee loans structured?
Is there a chart that outlines the application of seller concessions or contributions?
Is there a chart for disclosing originator compensation on the Good Faith Estimate?
Is there a chart for applying broker credits to the borrower?
Is there a chart for applying limits to interest rate credit (above par pricing)?
Is there a chart for determining the broker compensation amount?
In a compensation tier, may an interest rate be chosen below the originator's tier?
May an interest rate below a compensation tier require the borrower to pay the discount?
In a delayed closing, how is a rate lock extension treated?
On the GFE, where are lender costs placed resulting from all adjustments?
Using a rate sheet, where is an originator's compensation placed on the GFE?
Why do many lenders pay compensation based on lock date versus the origination date?
How does a lender monitor that a premium does not pay the loan originator's fees?
How to disclose the appraisal pass-through fee on the GFE and the HUD-1?
Is it a valid changed circumstance to switch from a consumer paid to lender paid model?
In Texas, the doc prep is part of origination fee, so how is compensation applied?
Who pays for GFE tolerance violations?
In the consumer model, how to reconcile GFE borrower credit with broker compensation?
What happens to fees associated with refinances that occur after locking and/or submission?
How to disclose buying down the rate, specifically pertaining to Block 2 of the GFE?
Must the cost of the credit report be charged in the lender paid transaction?
Is there a “grace period” for relating to loan compensation errors on the GFE?
Does the anti-steering disclosure apply to both consumer paid and lender paid models?
May a recruitment fee be paid on loan transactions if the recruiter is not an LO?
Is a wholesale Account Executive considered a loan originator?
Are fixed overhead costs a factor in a loan originator compensation plan?
When is a third party fee deemed to be compensation?
May the interest rates vary based on the financing and consumer credit profile?
Must an originator establish a business relationship with a creditor to use the safe harbor?
What constitutes a “possible loan offer?”
Are loan officer employees of lenders required to issue an anti-steering disclosure?
For safe harbor protection, is three (3) the maximum number of loan options to disclose?
What happens if the safe harbor is not met?

FAQs OUTLINE

LOAN ORIGINATOR COMPENSATION

$125

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