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An MLO receives a base salary plus a year-end bonus calculated as 0.1% of the total dollar volume of loans that successfully close without any post-closing compliance issues. Six months later, if a loan develops compliance problems, the MLO must return a proportional amount of the bonus. This arrangement:

Correct Answer

B) Is permitted because it encourages compliance and loan quality

Compensation structures that promote loan quality, compliance, and performance are permitted under Dodd-Frank. Clawback provisions tied to compliance issues are encouraged as they align MLO incentives with proper loan origination practices.

Answer Options
A
Violates the prohibition on compensation based on loan performance
B
Is permitted because it encourages compliance and loan quality
C
Is prohibited because compensation cannot be subject to clawback provisions
D
Is only permitted for MLOs with more than 5 years of experience

Why This Is the Correct Answer

Compensation structures that promote loan quality, compliance, and performance are permitted under Dodd-Frank. Clawback provisions tied to compliance issues are encouraged as they align MLO incentives with proper loan origination practices.

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