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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?
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.
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