Monday, December 6, 2010

Top 10 Thoughts on Frank-Dodd/LO Comp

It may be getting colder outside but the discussions regarding LO comp are starting to heat up. Seminars and webinars are being offerred on a weekly, if not daily basis by compliance attorneys and law firms. Here's my "Top 10" take to get you thinking...

1. Do you have branch offices running a P&L? Does the manager originate? This model will have to chenge.

2. Do partners/owners originate? This is another no-no for most.

3. Commission can no longer be uised to offset certain fees. This means renegotiations, extensions, escrows etc - they'll be paid for by the client (good luck) or the lender (yikes). Don't overlook this, it could be a BIG drain on revenue.

4. Is it time to update lock procedures and requirements?

5. How are you evaluating Loan Officers, branches and even wholesale accounts? Volume, pull through, and quality are some of the key factors in determining a fair compensation model. Don't forget these data sets are dynamic - not static!

6. Have a wholesale platform? How will your pricing and compensation stack up against others? Will you be competitive in the land of "safe habors"?

7. Allow your retail to broker out loans? What's your plan to ensure "safe harbor"?

8. What's your timeline to formulate and plan, announce and go live? Waiting til April 1?

9. Beware of the bonus. It could be dangerous to try to find loop holes or work-arounds here.

10. Is your current model based on splits? What about new model? How will these updates affect the forms bottom line?

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