Regulatory Alerts2012-04-05
CFPB Bulletin 2012-02: Clarification on Loan Originator Compensation and Qualified Plans
The Consumer Financial Protection Bureau issued Bulletin 2012-02 to clarify how Regulation Z compensation rules apply to employer contributions to qualified profit-sharing, 401(k), and employee stock ownership plans. The Bureau states that these rules permit financial institutions to fund such qualified plans for loan originators using profits derived from mortgage loan originations. This guidance addresses specific inquiries regarding qualified plans while noting that further clarification on non-qualified profit-sharing arrangements will be provided through future rulemaking.
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