Brief Reputation For the Rule
The first iteration of the loan officer compensation rule did not stem from the Dodd-Frank Act unlike many other CFPB rules. In August of 2009, the Board of Governors regarding the Federal Reserve System (Board) issued a proposed guideline on loan originator payment. The Dodd-Frank Act had been enacted on July 21, 2010 and included limitations that closely, yet not completely, implemented the Board’s proposed rule; but, not as much as 30 days following the Dodd-Frank Act ended up being enacted, the Board finalized its guideline. The Board acknowledged that there have been differences when considering its guideline in addition to Dodd-Frank Act, however the Board determined that delaying its guideline would damage customers.
The Board’s final rule became effective on April 6, 2011. Continue reading “Subtitle A: Loan Originator Compensation Restrictions and Enforcement”