“We are going to have a sales contest this month. The winners will get to enter next month’s contest.” Hardy har har, right? (Note: watch Glengarry Glen Ross.) As rumors swirl, and you know what they say about rumors, about the FHFA rescinding recent changes to its loan level price adjustment matrix this afternoon, I received this note. “Hey Rob, do you think that the CFPB is wise to some lenders switching referral sources to switch commission structures? Like where a loan comes in off the street, and a price is quoted with 1.25 for the LO, and client balks, so then the loan is referred in-house and the LOs commission knocked down to .50 to keep the deal?” Yes, I have heard that they are and the CFPB is probably aware of those kinds of things too, but you should check with your lawyer or compliance department to see if that runs afoul of LO comp rules. Whether the original street LO receives zero commission when a loan goes to the in-house team/call center, or is paid a lower commission, you will want to get qualified counsel about this. You can also always submit a regulatory inquiry to the CFPB. And anyone can always report something anonymously here. (Today’s podcast can be found here and this week’s is sponsored by SimpleNexus, an nCino company and the homeownership platform that unites the people, systems, and stages of the mortgage process into one seamless, end-to-end solution. Part one of an interview with FundingShield’s Adam Chaudhary on protecting against wire and title fraud.)
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