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Tag: vendor management

1 article tagged “vendor management”
Compliance

Regulation Z 1026.36 Loan Originator Compensation and Where AI Vendor Pricing Sits: The Terms-Based Comp Prohibition, the Person-Definition Question, and How the Vendor Contract Has to Read

The Loan Originator Compensation rule at Reg Z 1026.36 prohibits paying an individual loan originator based on the terms of the loan, and it defines 'loan originator' broadly enough to swallow the AI vendor conversation. The person-definition analysis, the compensation-attribution question that a per-loan vendor fee raises, and the contract structure that keeps the AI vendor's economics outside the LO Comp perimeter.

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