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I just attend a Reg Z training yesterday and now I’m questioning our Profit Sharing Bonuses that I thought we had all figured out. We have a small group of employees that receive a quarterly profit sharing bonus. Back when the new compensation rules came out we removed all of the loan officers from this group. We thought by doing this we were in compliance. However in training it was described that anybody could be considered a loan originator. Does this mean if our IT guy is in this group and refers a family member to a loan officer for a refinance he is considered a loan originator and hence we can not give him his quarter profit sharing bonus??
You obviously paid very close attention to our discussion yesterday. Your conclusions are correct.
Remember the CFPB has promised to address this in a future rulemaking and we expect that rulemaking in the coming weeks. Hopefully we will get a good answer that resolves your problem.
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