Loan Originator Compensation Rules


Presented by: Mary Beth Guard and Andy Zavoina

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Several separate rulemakings have addressed loan originator compensation under Regulation Z, and new tweaks to the rule on this subject have been adopted as recently as September 13, 2013. It's a hot topic, and it's an area you don't want to screw up.

You have to be able to definitively determine who is subject to the compensation restrictions, what types of loans carry with them the prohibition against LO compensation being tied to rates and terms. (And don't confuse Mortgage Loan Originators under the SAFE Act with loan originators for Reg Z comp purposes. Totally different triggers for the two! It's possible for someone to be an LO but not an MLO and vice versa.) How can you construct bonuses for those who are covered? What can you contribute to a deferred compensation plan for them? What compensation structures are permissible - and which ones will get you in regulatory hot water?

From issues relating to dual compensation, mortgage brokers, and timing considerations, there is a great deal to wrap your head around. And, as you might expect, detailed new record retention requirements to boot.

We will start with the basics of loan originator compensation and follow through with ideas on practical application. After this program, you will be prepared to review your LO compensation structure for compliance and rework it, if necessary to ensure it conforms to the new rules.

About the Speakers: Mary Beth Guard has been teaching financial privacy to bankers since the early 1990s and has authored more than a hundred articles on private-related subjects. In addition, she has created privacy cheat sheets and matrices used by thousands of bankers nationwide. Currently serving as Executive Editor of, Mary Beth has had a long and distinguished career, focusing on the banking industry since 1984. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association and General Counsel for the Oklahoma State Banking Department.

Mr. Andy Zavoina, CRCM, is a consultant with the Glia Group, best known for its involvement with

Andy has been in finance and banking for 22 years. Over 20 years were with a holding company with two Central Texas community banks that had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. After starting in loan workouts, Mr. Zavoina has been a consumer, commercial and real estate lender and managed those departments as well as being the banks first Webmaster. He was responsible for compliance, management, auditing, and training for both banks.

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CD-ROM Includes:
  • Complete presentation (including slides and audio)
  • Written Materials
  • Follow-up Q & A
You have the right under this license agreement for this CD-ROM to use this presentation on a single-workstation. Use on a network is in violation of the copyright agreements. CD may be used by multiple users at a given institution but may not be placed on a network or in any other multi-user environment.

This program was recorded in its entirety in November 2013. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_loanorig1013
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Friday 04 October, 2013.

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