Yes, we believe the loan originator compensation rules permit financial institutions to pay loan originator compensation that is based on the quality of a loan file. As stated in the staff commentary:

“Permissible methods of compensation.—Compensation based on the following factors is not compensation based on a term of a transaction or a proxy for a term of a transaction: . . . . (G) The quality of the loan originator’s loan files (e.g., accuracy and completeness of the loan documentation) submitted to the creditor.” Official Interpretations, 12 CFR 1026, Paragraph 36(d)(1), Comment 2(i).”