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1 Revisions to Loan Originator Compensation & Qualifications Under TILA Nancy Schoolman Senior Managing Consultant Sheldon Hendrix Managing Consultant August 27, 2013 To Receive CPE Credit Participate in entire webinar Answer polls when they are provided If you are viewing this webinar in a group o Complete group attendance form with Title & date of live webinar Your company name Your printed name, signature & address o All group attendance sheets must be submitted to within 24 hours of live webinar o Answer polls when they are provided If all eligibility requirements are met, each participant will be ed their CPE certificates within 15 business days of live webinar 2 1

2 Background of the Revisions The 2010 Dodd-Frank Wall Street Reform & Consumer Protection Act (DFA) added consumer protections regarding: o Loan originator compensation o Qualifications & registration or licensing of loan originators o Mandatory arbitration clauses & the financing of singlepremium credit insurance o Written compliance policies & procedures for depository institutions 3 Background of the Revisions (continued) In addition, this final rule revises & clarifies commentary on existing loan originator compensation provisions, including: o Prohibitions on dual compensation o Compensation based on a term of a transaction or a proxy for a term of a transaction The final rule also establishes tests for when loan originators can be compensated through certain profits-based compensation arrangements The Consumer Financial Protection Bureau s (CFPB) final rule for Loan Originator Compensation & Qualifications is effective January 10,

3 Scope These rules cover: Closed-end consumer loans secured by a dwelling o Residential mortgages o Home equity term loans o Construction loans o Bridge loans o Loans for second homes o Loans for vacation homes (not timeshares) o Loans/lines for mobile homes o Reverse mortgages HELOCs: The Rule s restrictions on mandatory arbitration clauses & financing of credit insurance premiums apply to open-end home equity lines of credit secured by the consumer s principal dwelling 5 Who is a Loan Originator? Loan Originator (LO) is a person who, in expectation of direct or indirect compensation or other monetary gain or for direct or indirect compensation or other monetary gain, performs any of the following activities: o Takes an application o Assists a consumer in obtaining or applying to obtain consumer credit o Offers or negotiates consumer credit terms o Arranges consumer credit o Refers a consumer to a loan originator o Otherwise obtains or makes an extension of consumer credit for another person o Through advertising or other means of communication represents to the public that such person can or will perform any of these activities 6 3

4 Who is a Loan Originator? (continued) o o o A person referring a consumer to any person who participates in the origination process as an LO. Referring includes any oral or written action directed to a consumer that can affirmatively influence the consumer to select a particular LO or creditor to obtain an extension of credit when the consumer will pay for such credit. LO includes an employee, agent or contractor of the creditor or loan originator organization if the employee, agent or contractor meets this definition (aka Individual Loan Originator ) A financial institution is an LO only in a table funded transaction (financial institution does not finance the transaction at consummation out of its own resources, including by drawing on a bona fide warehouse line of credit or out of deposits held by the financial institution) (aka Loan Originator Organization ) 7 Who is Not a Loan Originator? LO does NOT include: o Someone who performs purely administrative or clerical tasks on behalf of a loan originator or creditor (but does not take consumer credit applications or offers or negotiates credit terms) o Processors, underwriters & closers o Servicers or a servicer s employees (so long as they do not offer or negotiate a transaction that constitutes a refinancing under regulation Z) o Real estate brokers performing only real estate activity o Employees of manufactured home retailers o Seller financers Also, providing a general explanation, information or descriptions in response to consumer inquiries (such as explaining terminology or lending policies) would not be included as an LO 8 4

5 Compensation Rules (continued) Currently cannot pay compensation based on transaction s interest rate or any terms or conditions or a proxy of a term of a covered transaction Revision expanded transaction terms & conditions to include term of a transaction, defined as any right or obligation of the parties to a credit transaction, except for the amount of credit extended o Includes credit transaction terms stated in a promissory note, security agreement, deed of trust or other contract o Payment of fees related to the extension of a credit, including loan originator fees o Payment of any fees or charges imposed on the consumer (if required to be disclosed in a GFE, HUD-1 or HUD-1a) 9 Compensation Rules (continued) The new definition of compensation includes salaries, commissions & any financial or similar incentives. This includes: o Annual or other periodic bonuses o Awards of merchandise, services, trips or similar prizes o Any fees retained by a loan originator, regardless of how they are characterized 10 5

6 Compensation Rules (continued) Proxy for Terms: If both the following two conditions are met, then the factor is a proxy, & a loan originator s compensation may not be based on that factor: o The factor consistently varies with a transaction term over a significant number of transactions o The LO has the ability, directly or indirectly, to add, drop or revise the factor in originating the transaction 11 Compensation Rules (continued) o Proxy example: Compensation based on whether an extension of credit is held in portfolio or sold into the secondary market could violate the proxy provisions Proxy Example #1- if a creditor pays a higher bonus for covered transactions held in portfolio than for those sold to the secondary market & the creditor keeps only fixed rate balloon loans with maturities of 5 years in the portfolio while the secondary market transactions are fixed rates with no balloon feature & are amortized over 30 years, the proxy of a term is evidenced by the consistency of the factor varying over a significant number of transactions (existence of a balloon feature) & the LO s ability to change the factor by advising the consumer to choose portfolio loan to increase compensation 12 6

7 Compensation Rules (continued) Example of compensation not in violation of proxy prohibitions: o An hourly rate of pay to compensate the LO for the actual number of hours worked o Compensation based on an LO s overall dollar volume o A payment that is fixed in advance for every loan the LO arranges for the creditor o The percentage of applications submitted by the LO to the creditor that results in consummated transactions o Whether consumer is existing customer of the creditor or a new customer o Compensation based on the long-term performance of the LO s loans o Compensation based on quality of an LO s loan files o Allow reductions in loan originator compensation to cover unanticipated increases in closing costs from non-affiliated third parties under certain circumstances 13 Dual Compensation Rules Rule codified that if an LO receives compensation from the consumer, they cannot receive compensation from any other source, at, before or after loan consummation o Exception: If LO organization receives compensation from the consumer, compensation may be paid to the individual LO. 14 7

8 Bonuses, Profit Sharing Plans & Contributions to Employee Plans Compensation based on the terms of multiple transactions by an individual LO or the terms of multiple transactions by multiple LOs is not allowed unless expressly permitted by other provisions of this final rule Pooled compensation - Comment 36(d)(1)-2.iii indicates where LOs have different commission rates or other compensation plans & they each originate loans with different terms, (d)(1) does not permit the pooling of compensation so that the LOs share in moneys from that pool Rule permits compensation in the form of a contribution to a defined contribution plan that is a designated tax-advantaged plan (e.g., 401(k)) or a benefit under a defined benefit plan that is a designated tax-advantaged plan 15 Non-Deferred Profits-Based Compensation Plan Rule permits compensation to LO under a non-deferred profits-based compensation plan so long as certain criteria are met o Compensation may not be directly or indirectly based on the terms of that individual LO s transactions, i.e., creditor may not pay an LO a larger amount under a Profit Sharing Plan if that LO s transactions averaged a higher interest rate or higher average fees than other LO s o Compensation does not exceed 10% of the individual LO s total compensation for the same period or LO originated 10 or fewer transactions during the 12-month period preceding the date compensation is determined Profits-based compensation which excludes mortgage-related business is not subject to the 10% limit 16 8

9 Non-Deferred Profits-Based Compensation Plan (continued) 10% Limit applies to total compensation which is the total of: o All wages & tips reportable for Medicare tax purposes o Box 5 on W-2 Reportable Compensation on IRS 1099-MISC if LO is contractor At the election of the person paying the compensation, all contributions by the creditor to the individual LO s accounts in designated tax-advantaged plans that are defined contribution plans, i.e., 401(k) account 17 Non-Deferred Profits-Based Compensation Plan (continued) A non-deferred profits-based compensation plan is defined as any arrangement for the payment of non-deferred compensation that is determined with reference to the profits of the person from mortgage-related business o These plans include, without limitation, bonus pools, profits pools, bonus plans & profit-sharing plans Compensation is defined to include bonuses, awards or merchandise, services, trips or similar prizes or incentives where these are determined based on the profitability of the person, business unit or affiliate 18 9

10 Record Retention Requirements Creditors must maintain records sufficient to evidence compensation payments & copy of compensation agreement governing payments Record retention for LO compensation is three years after the date of payments o Payment records o Calculation records o Compensation agreements that govern payments 19 LO Qualification & Identification Requirements LOs must be registered or licensed in accordance with the SAFE Act & other applicable laws For individual LOs who are not required to be licensed, the following must be obtained: o Criminal background check o Credit report Based on information obtained, it must be determined: 20 o o o LO has not pleaded guilty or nolo contendere to a felony in past seven years Has never pleaded guilty or nolo contendere to a felony involving fraud, dishonesty, breach of trust or money laundering Demonstrated financial responsibility, character & general fitness 10

11 LO Qualification & Identification Requirements (continued) Periodic training must be provided to LOs to cover the requirements of Federal & State laws that pertain to its originator activities Name & NMLSR ID of LO (including creditor) o Name & NMLSR IDs of LOs required, at a minimum: On credit application Note or loan contract The security instrument o If multiple NMLSRs associate with a transaction, information of the individual LO with primary responsibility for the transaction is required to be provided on these documents 21 Arbitration Clauses Effective June 1, 2013 Ban on Mandatory Arbitration o Prohibition on mandatory arbitration clauses in contracts for consumer closed-end credit secured by a dwelling, or HELOCs secured by the consumer s principal dwelling o Prohibition on mandatory waivers of consumer rights to bring a claim in court, i.e., waivers of Federal statutory causes of action) o Consumer & creditor may agree to use arbitration or other non-judicial procedures after dispute arises 22 11

12 Financing of Single-Premium Credit Insurance * Creditor cannot finance, directly or indirectly, any premiums or fees for credit insurance in connection with covered transaction o Does not apply to credit insurance for which premiums & fees are calculated & paid in full on a monthly basis o Mortgage insurance premiums may still be financed The term credit insurance is defined by the Rule as credit life, credit disability, credit unemployment or credit property insurance, or any other accident, loss of- income, life or health insurance, or any payments directly or indirectly for any debt cancellation or suspension agreement or contract o Applies to all closed-end consumer credit secured by a dwelling & HELOCs secured by a consumer s principal dwelling 23 *As of May 8, 2013, temporarily delayed. On June 24, 2013, CFPB announced it may be effective January 10, 2014 or earlier. Policies & Procedures Creditors must maintain written policies & procedures covering: o LO compensation requirements o LO qualification requirements o LO identification requirements o Steering prohibitions 24 12

13 Exemption for Alternative No-Fee Loan Option As part of final rule, creditors were exempted from requirement to provide the consumer a comparable, alternative loan with no upfront discount points, origination points or fees that are retained by the creditor, broker or an affiliate of either (a "zero-zero alternative") before imposing upfront points &/or fees in a closed-end mortgage transaction CFPB stated that it will delay action on this provision & continue to study the market & potential impact of this 25 Next Steps Verify no mandatory arbitration clauses are included in contracts for applicable transactions Identify employees within your organization who are covered by the definition of loan originator Review compensation policies, contracts & practices to evaluate their compliance with the revised compensation rules Formalize record retention content for LO compensation o Payment records o Calculation records o Compensation agreements Adopt required policies & procedures Train employees 26 13

14 Resources Final Rule: CFPB s Loan Originator Rule / Small Entity Compliance Guide: CFPB s 2013 CFPB Dodd-Frank Mortgage Rules Readiness Guide / Version Nancy Schoolman Senior Managing Consultant Sheldon Hendrix Managing Consultant

15 Continuing Professional Education (CPE) Credits BKD, LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: The information in BKD webinars is presented by BKD professionals, but applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor before acting on any matters covered in these webinars. 29 CPE Credit Up to 1 CPE credit will be awarded upon verification of participant attendance; however, credits may vary depending on state guidelines For questions, concerns or comments regarding CPE credit, please the BKD Learning & Development Department at 30 15

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