Please remember that the successful economy in the United States has been built on free enterprize. Competition helps everything and everybody. Competition makes everything better. If a product or service is not competitively priced, the consumer should not have to pay for that product or service and should be able to choose a product that meets their needs. Some Loan Officer Compensation Rules leave Loan Officers at a disadvantage when trying to compete for business. Please try not to place a Loan Officer at a disadvantage when competing for business.
Requiring that a Loan officer only be paid a salary or an hourly wage, when a borrower pays an origination fee, or another fee to a Lender, limits a Loan Officer's ability to compete. Let's face it, companies can't stay in business unless they are profitable. Deriving a Loan Officer's income from a borrower can be an advantage to a borrower and will almost always lead to the borrower paying a lower interest rate, in a competitive environment. Borrowers are sophisticated and educated today. They know that they need to shop for a mortgage product. By requiring that a Loan Officer be paid only an hourly wage or a salary, if compensation is collected from a borrower, limits a borrower's ability to obtain a lower rate by paying a Loan Officer's income in cash. If a Loan Officer's income is not paid in cash by the borrrower, it must come from the Lender which leads to higher interest rates. Mortgage companies can't afford to pay their loan officers a salary or an hourly wage. Mortgage companies need to be able to pay Loan Officers based on the income they bring into the company.
Believe it or not, dual compensation can be a way to offer a more competitivly priced product to a consumer. If all of a company's compensation is derived from a lender, a borrower may be paying a higher interest rate than what he would be paying if some of the mortgage company's compensation was paid by the consumer
Comment on CFPB-2012-0037-0049
This is comment on Proposed Rule
Truth in Lending Act (Regulation Z); Loan Originator Compensation
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