Legal Blog

Compensation and Compliance Matters: Why LO Comp ‘Pick-A-Pay’ gets Picked On (Part One)

The so-called loan officer compensation pick-a-pay-plan is often at the center of controversy regarding its illegality. I believe the reason for this is not so much the concept as its implementation. In other words, depending on how the plan is set up and utilized its compliance level will dramatically change. This will be the first in a series explaining the serious mistakes being commonly made in connection with the use of these compensation strategies. While there are compliant ways to institute these plans, many employers make the mistake of having several “buckets” that vary by a few basis points. Essentially each loan officer has a customized plan that they can change every quarter or so. These plans are truly designed for each loan officer and can change or vary from loan officer to loan officer by a few basis points. Click here to read the entire article If you have any questions about ‘Pick-A-Pay’ plans please contact Ari Karen at: Bank Manager | 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.