An MLO works for a company that pays a base commission plus an additional 'complexity fee' for loans that require more than 20 hours of processing time, regardless of loan terms. The complexity fee is the same dollar amount for all qualifying loans. This additional compensation:
Correct Answer
B) Is permitted because it compensates for additional work performed
Compensation based on the amount of work or time spent on a loan is permitted under Dodd-Frank, as long as it's not tied to the loan's financial terms. Payment for additional processing complexity is considered compensation for services rendered.
Why This Is the Correct Answer
Compensation based on the amount of work or time spent on a loan is permitted under Dodd-Frank, as long as it's not tied to the loan's financial terms. Payment for additional processing complexity is considered compensation for services rendered.
More Origination Questions
A borrower has a construction-to-permanent loan with a 12-month construction phase. At month 10, construction is only 60% complete due to delays. What is the most likely outcome?
For a construction-to-permanent loan, when must the initial Closing Disclosure be provided for the construction phase?
During a refinance transaction, the appraiser determines that significant unpermitted additions were made to the property. The appraiser wants to discuss this with the MLO before finalizing the report. What should the MLO do?
An appraiser discovers that a property has significant foundation issues that were not disclosed. The appraiser reduces the property value by $25,000 and includes detailed comments about the structural problems. The loan officer is upset because this will kill the deal. Under AIR, the loan officer:
An MLO's compensation structure includes higher payments for certain loan products. When is it acceptable to recommend these higher-compensated products?
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