Dodd/Frank Originator Compensation Documentation
Attached please find a draft of the detailed compensation policies we are assembling to
assist you in meeting the 4/1/2011 deadline to put these into effect. If you purchased
your product after 9/23/2010, there was a section in your module that dealt with the three
major issues of prohibiting dual compensation, prohibiting direct payments to employees,
and anti-steering. This policy is designed to supplement that section.
- Quality Control Plan – Originator Compensation Section (post 9/23/2010 customers)
- Quality Control Plan – Combine with 9/23/2010 update available at
- Origination Module – Compensation Section
It is important to note that these are a DRAFT because we do not yet have a clear picture
of the literal requirements of the rule due to many conflicting interpretations in the
original rule and subsequent opinions. QuickStart Mortgage Manuals will continue to
work with you as the industry arrives at a more standard best practice.
As always, if you receive feedback from an investor, regulator or agency in writing, we
will assist you in answering or rebutting.
This update contains 1 form – the “Borrower’s Best Interest Disclosure” (anti-steering)
and the policy itself. You may download the update from