By Jason Sharon · Veteran-Owned Mortgage Broker · NMLS #1281448Call (843) 569-7283
Loan Officer Success Manual Download Free PDF
The rule behind every paycheck

How Loan Officers Can and Cannot Be Paid

Regulation Z decides how a loan officer can be compensated, and it is one of the most enforced rules in mortgage lending. The core is one idea: your pay cannot depend on the terms of the loans you make. Everything else in the rule protects that idea from workarounds.

The core rule

No loan originator may receive, and no one may pay a loan originator, compensation based on a term of a transaction: the rate, the fees, the product, or any other right or obligation of the parties. That also covers terms across multiple transactions by one or several loan officers.

It reaches proxies too. A factor that is not itself a loan term counts as one if it consistently varies with a term over many transactions and the loan officer can add, drop or change it.

Allowed

A fixed percentage of the amount of credit extended, with or without a minimum or maximum dollar amount.

Not allowed

More pay for a higher interest rate, a particular product, or added fees.

Bonuses, retirement plans and who pays

Retirement plan contributions

Contributions to qualified plans such as a 401(k) are allowed, as long as a defined contribution is not based on your loans' terms.

Profit-based bonuses

Allowed if not based on your loans' terms and either the bonus is no more than 10 percent of your total pay for the period, or you originated 10 or fewer loans in the prior 12 months.

Dual compensation

If a borrower pays the loan originator directly, the originator generally cannot also be paid by anyone else on that loan.

Steering, and why brokers show options

A loan originator may not steer a borrower into a loan because it pays the originator more, unless the loan is in the borrower's interest. The rule's safe harbor asks the originator to get options from a significant number of the lenders it regularly works with and, for each type of loan the borrower wants, present the lowest-rate option, the lowest-rate option without risky features, and the option with the lowest total points and fees.

That safe harbor describes what a good broker does anyway: shop, then show. It is one reason the manual makes the case for brokering. The licensing floor that comes first is on getting licensed.

Federal minimums from Regulation Z, 12 CFR 1026.36(d) Prohibited payments to loan originators and (e) Prohibition on steering. States can and do require more; check your state regulator through NMLS. Not legal advice.

LO compensation FAQ

Can a loan officer be paid more for a higher interest rate?
No. Regulation Z prohibits compensation based on a term of the transaction, including the interest rate, or on a proxy for a term.
Can a loan officer be paid a percentage of the loan amount?
Yes. The amount of credit extended is not treated as a term of the transaction when compensation is a fixed percentage of it, which may have a minimum or maximum dollar amount.
Can loan officers get bonuses based on company profits?
Yes, within limits: the bonus cannot be based on the terms of that officer's loans, and either it is no more than 10 percent of the officer's total compensation for the period or the officer originated 10 or fewer loans in the prior 12 months.

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