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Loan Originator Compensation and Profit Sharing/401(K) Contributions

Financial Institutions

September 14, 2011
by Tim Tedrick, CRCM, CRP, Thomas Krieg, CPA

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Tim Tedrick Tim Tedrick, CRCM, CRP
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Thomas Krieg Thomas Krieg, CPA
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In April of 2011, the amendment to Regulation Z that prohibits payments to loan originators based on the terms or conditions of the transaction other than the amount of credit extended became effective. For many depository institutions, this seemed a nonevent, while for other depository institutions and mortgage brokers, it was a huge shift in the way compensation was paid. However, for any entity that has a profit sharing/401(k) plan and that is also subject to the provisions of the amendment, there is more to consider.

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