Wondering if this would be in violation of the Loan Originator Compensation Rules.
Our bank would like to start giving our junior loan officer some kind of commission.
The fee income we earn from our portfolio loans is less than the fee income we earn from the loans we sell on the secondary market. We generally charge the same fees to the customer for both.
I know that we get in trouble if we give commission based on anything other than loan amount. We were wondering if we could pay a lower rate/loan amount for portfolio loans in comparison to those we sale on the secondary market.
Keep in mind, this could encourage the loan officer to steer the borrower to the secondary market, but that would be in the best interest of the customer, as the rate is lower/fixed (whereas our portfolio loans are higher/variable).