Legal Blog

Compensation and Compliance Matters: How LO-to-LO Referrals Become Problems

At a glance, it would seem that there should be no problem with one loan officer referring a loan to another loan officer in the same branch and/or for a branch manager to refer loans to his/her loan officers. In fact, such a situation could create significant regulatory problems for a lender. In the comments on the LO compensation laws, the Consumer Financial Protection Bureau made a point to mention that actions aimed at circumventing the rules would not be permissible. One example was a lender who created or permitted teams of LOs to share commissions. The CFPB believed such relationships could lead to loans being passed back-and-forth to achieve a tiered pricing or product allocation between two or more loan officers at different compensation levels. Click here to read the rest of the article If you have any questions about qualified mortgage rule loans please contact Ari Karen at: Bank Manager Reimbursementsakaren@offitkurman.com | 240.507.1740 | Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others. You can also connect with Offit Kurman via FacebookTwitterGoogle+YouTube, and LinkedIn.