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Any bank employee that makes a mortgage loan referral to our bank’s mortgage company subsidiary earns $100 if the loan originates. 1. Does that make all employees LOs? 2. Since we currently have a screening process for hiring (credit and background check) are employees hired prior to 1/10/2014 grandfathered, and only employees hired 1/10/2014 or after subject to the criminal background check, credit report, and criminal/civil/administrative findings questions as answered by the LO? 3. Are all employees subject to the subsequent reviews if we know of reliable information indicating the LO likely no longer meets the standards?
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