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A mortgage company implements a 'quality bonus' system where MLOs receive additional compensation if their loans have fewer than 2 conditions at underwriting. The bonus amount is the same regardless of loan size or type. This compensation structure:

Correct Answer

B) Is permitted because it encourages loan quality without being based on loan terms

Dodd-Frank permits MLO compensation based on factors that promote loan quality and performance, such as fewer underwriting conditions, as long as the compensation is not tied to specific loan terms like interest rate, points, or fees.

Answer Options
A
Violates Dodd-Frank because it's based on underwriting outcomes
B
Is permitted because it encourages loan quality without being based on loan terms
C
Is prohibited because it could influence MLO behavior regarding loan applications
D
Is only permitted if approved by the CFPB in advance

Why This Is the Correct Answer

Dodd-Frank permits MLO compensation based on factors that promote loan quality and performance, such as fewer underwriting conditions, as long as the compensation is not tied to specific loan terms like interest rate, points, or fees.

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