Directors' Resource Center
Technical Assistance Video Program
Loan Originator Compensation Rule
- LO Comp Rule Purpose, Coverage and Overview; “Loan Originator” and “Compensation” Defined
- Loan Originator Compensation Based on Loan Terms or Proxies Is Prohibited; Exceptions for Profits-Based Compensation
- Other Compensation Aspects of the Rule; Record Retention Requirements and Required Policies and Procedures
- Building an Effective Compliance Management System (CMS) for the LO Comp Rule; Presentation Recap and Resources
Approximate run time 04:02
Approximate run time 23:54
III. Loan Originator Compensation Based on Loan Terms or Proxies Is Prohibited; Exceptions for Profits-Based Compensation
Segment three delves into the rule’s compensation provisions in depth, focusing primarily on the prohibition against loan originator compensation based on loan terms or proxies for loan terms. This segment examines what are loan terms under the rule and how to analyze whether a factor that is not a loan term may be a “proxy” for a loan term. This segment also examines the rule’s exceptions allowing for certain profits-based compensation; community banks may find these exceptions of particular benefit to their mortgage lending operations.
Approximate run time 18:34
IV. Other Compensation Aspects of the Rule; Record Retention Requirements and Required Policies and Procedures
Segment four examines the permissibility of pricing concessions and the practices of dual compensation and steering. This segment also reviews the rule’s record retention requirements and its requirement to establish and maintain written policies and procedures.
Approximate run time 09:36
V. Building an Effective Compliance Management System (CMS) for the LO Comp Rule; Presentation Recap and Resources
This segment focuses on what institutions could consider when building and maintaining an effective compliance management system for the LO Comp Rule, and offers some practical tips for ensuring compliance. The segment then closes out the LO Comp Rule video presentation by briefly reviewing the topics covered and highlighting those aspects of the rule that should prove helpful to community banks. Finally, this segment lists resources to consult for additional information about the LO Comp Rule.
Approximate run time 08:49