Loan Originator Compensation - 330 FAQs

Lenders Compliance Group


330 Questions and Answers 

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Version 14 - June 6, 2011

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?




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