LO Comp Lessons – Advanced Studies
Recorded Sept. 16, 2015
More than 18 months after the revised loan originator compensation rule went into effect, lenders are still wrestling with how to make sure their pay plans line up not only with the Truth in Lending Act and Regulation Z, but also a host of other requirements – ranging from state laws to fair lending requirements. Much of the confusion stems from what many in the mortgage industry have categorized as a combination of unclear guidance and strict enforcement from the Consumer Financial Protection Bureau on the far-reaching compensation regulation.
The CFPB has taken a number of supervisory and enforcement actions related to LO comp, finding fault with lenders for not maintaining written policies and procedures related to LO comp, for allowing loan originators to receive income based on the profitability of loans they originated, and for maintaining point bank type arrangements. These actions have led to criticism from some in the industry that the bureau is setting policy through enforcement rather than rules and guidance. As a result, they feel lenders are left to guess if and when they may be penalized for their LO comp decisions.
Join Inside Mortgage Finance for “LO Comp Lessons – Advanced Studies,” a look at the CFPB’s LO comp supervision and enforcement plan, how it should guide your policies, and what LO compensation strategies you should and should not consider.
- Richard Andreano, Mortgage Banking Group Practice Leader, Ballard Spahr
- Kristie Kully, Partner, K&L Gates
- Benjamin Olson, Partner, BuckleySandler
Among the topics covered, we’ll look at LO comp lessons to be learned from:
- CFPB supervisory actions.
- CFPB enforcement actions.
- Fair lending laws.
- Federal and state employment laws.
Please note:The recording contains both an integrated audio/video copy of the conference as well as an audio-only version.