FDIC Statement on CFPB Bulletin 2012-02: Payments to Loan Originators Based on Mortgage Transaction Terms or Conditions under Regulation Z
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FDIC Statement on CFPB Bulletin 2012-02: Payments to Loan Originators Based on Mortgage Transaction Terms or Conditions under Regulation Z

Filetype[PDF-1.21 MB]



Details:

  • Publisher's site:
  • Description:
    The Consumer Financial Protection Bureau (CFPB) issued Bulletin 2012-02 on April 2, 2012, to provide additional guidance on permissible forms of compensation to loan originators under the Truth in Lending Act - Regulation Z's Compensation Rules (12 C.F.R. ยง 1026.36). The Bulletin addresses whether and how the Compensation Rules apply to qualified profit-sharing, 401(k), and employee stock ownership plans (collectively, Qualified Plans). Specifically, the CFPB indicates that the Compensation Rules permit employers to contribute to Qualified Plans out of a profit pool derived from mortgage originations. The CFPB does not provide guidance on profit-sharing arrangements or plans that are "not in the nature of Qualified Plans," but indicates it anticipates providing greater clarity in a future rulemaking.
  • Content Notes:
    Cites 75ย Fed. Reg.ย 58509, 9/24/2010|Regulation Z: Truth in Lending

    Cites 76ย Fed. Reg.ย 79768, 12/22/2011|Truth in Lending (Regulation Z)

  • Format:
  • Release Date:
    04/17/2012
  • Update Date:
    11/26/2018
  • Withdrawn Date:
    12/01/2018
  • Agencies Involved:
    Federal Deposit Insurance Corporation (FDIC);Board of Governors of the Federal Reserve System (The Fed);Consumer Financial Protection Bureau (CFPB);
  • Fdic Employee Involved:
    Sandra Barker;Glenn Gimble;
  • Law Involved:
    Truth in Lending Act;Dodd-Frank Wall Street Reform and Consumer Protection Act;
  • Related Regulation:
    Regulation Z|;12 CFR Part 1026.36;
  • Source:
    FDIC Website
  • Memorandum To:
    FDIC-Supervised Banks
  • FIL Number:
    FIL-20-2012
  • Main Document Checksum:
  • File Type:

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