[dgrayson]

We would like to pay a flat fee to any employee that refers a mortgage loan to the bank and the mortgage loan is successfully closed. The fee would not be based on term or rate. We are preposing a $150 fee for a conforming loan and a $250 fee for a jumbo loan is this permissable?

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[JGo9]

In reading your question my thoughts go to the loan originator compensation rules.

If you are making payments to people that not Loan Originators as defined in the regulation, then I can’t think of an issue with it right off.

If you are thinking about paying this to loan originators, I’d have to do some research to be sure, but I think you would still be fine as it is not linked to the terms of the loan.

[jholzknecht]

The compensation rules referred by JGo9 are included in Regulation Z 1026.36.

[Author]

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