Dually Licensed Dawn
Dually LicensedForum Replies Created
-
The compensation structure for mortgage loan originators (MLOs) can be complex due to varying state laws and federal regulations. Here’s a clearer breakdown of the key points regarding MLO compensation as W-2 employees or 1099 independent contractors:
Federal Regulations
- Dodd-Frank Act: Under Regulation Z of the Truth in Lending Act, compensation for loan originators can be as W-2 wages or as 1099 income. This regulation acknowledges both forms of compensation without a specific mandate for one over the other. More details can be found in the federal register documents linked in your message.
- HUD Requirements: Direct Endorsement (DE) lenders must compensate affiliated loan originators as W-2 employees for FHA loans. However, third-party originators who are not DE approved by HUD can be compensated as W-2 or 1099 contractors.
- IRS Rules: According to the IRS, the classification of an MLO as a W-2 employee or a 1099 contractor depends on the degree of control the employer has over the work and the worker’s independence. This affects how payroll taxes are handled.
State Requirements
- Varied Requirements: States differ in how MLOs must be compensated. For instance, New Jersey requires W-2 compensation for MLOs to align with employment standards and direct supervision by the licensed lender. Conversely, Florida allows MLOs to be either employees or independent contractors.
- Specific Regulations: Each state has specific regulations that must be directly verified for compliance, as the rules for MLO compensation under state laws vary significantly.
Practical Implications
- Flexibility in Classification: At the federal level, loan originators can be classified as employees or independent contractors, as evidenced by NMLS registration options that include W-2 and 1099 classifications.
- State Compliance: Lenders and MLOs must comply with the states’ laws to avoid legal complications.
In conclusion, while federal law does not mandate specific compensation for loan originators, state laws may impose specific requirements. MLOs and their employers must carefully check state and federal regulations to determine the appropriate compensation structure. This nuanced approach helps to navigate the complexities of MLO compensation across different jurisdictions.
See 12 CFR Part 1026 https://www.federalregister.gov/documents/2013/02/15/2013-01503/loan-originator-compensation-requirements-under-the-truth-in-lending-act-regulation-z#footnote-132-p11352, pg. 11352. See also https://files.consumerfinance.gov/f/201301_cfpb_final-rule_loan-originator-compensation.pdf, pgs. 262-63, 274, and 517. If 1099 compensation were not permissible under the Reg. Z it would have been stated therein. On the contrary, Reg. Z specifically refers to both W-2 and 1099 as types of compensation.
-
This reply was modified 9 months, 3 weeks ago by Dawn.
federalregister.gov
Loan Originator Compensation Requirements Under the Truth in Lending Act (Regulation Z)
The Bureau of Consumer Financial Protection (Bureau) is amending Regulation Z to implement amendments to the Truth in Lending Act (TILA) made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The final rule implements requirements and … Continue reading
-
In Illinois, the compensation structure for loan officers can vary, and it’s essential to understand the rules. Let’s break it down:
- Federal Requirements:
- Dodd-Frank: The Truth in Lending Act (Regulation Z) addresses loan originator compensation. It allows for both W-2 and 1099 compensation. Loan originators can receive income reported on a W-2 or a 1099 form.
- HUD (Department of Housing and Urban Development): FHA-approved lenders must compensate individuals on a W-2 basis. However, this requirement applies only to direct endorsement (DE) lenders writing FHA loans. Third-party originators not approved by HUD do not fall under the W-2 requirement1.
- IRS Common Law Rules: The IRS considers behavioral control, financial control, and the relationship between parties to determine whether compensation should be classified as W-2 or 1099. The responsibility for remitting payroll taxes depends on this classification1.
- State-Specific Regulations:
- While federal law doesn’t mandate W-2 compensation for loan originators, state laws may differ. It’s crucial to check Illinois-specific regulations to ensure compliance.
- NMLS (Nationwide Multistate Licensing System):
In summary, loan officers in Illinois can be paid via 1099, but it’s essential to consider both federal and state requirements. Always consult legal and financial professionals to ensure compliance with the specific rules that apply to your situation.
innovativemlo.com
W-2 vs. 1099 Compensation Not so Fuzzy After All
Successfully capture and write more business on Innovative's 100% compensation platform. Set your own compensation. Learn More.
- Federal Requirements:
-
LOL. Yes, silver keeps on going up. Price of silver per ounce hit $30 per ounce last week. You have the big banks and globalists scared shitless because of being short millions of ounces of silver. Silver is a great buy today and hands down will go over $100 per ounce and has potential of going over $1,000 per ounce.
https://www.youtube.com/watch?v=siWRrg_Uekc&ab_channel=BaldGuyMoney
-
I am seeing a lot more loan officers leaving the Mortgage Industry daily.
-
Great tiny house. Amazing how beautiful these manufactured homes that are tiny houses are.
-
When does the three day time clock start. If the loan closed today, Monday April 22, 2024, when is the three day over and a refinance loan going to fund?
-
The proliferation of electric vehicles (EVs) has led to a growing demand for electric car charging stations. These stations are essential for powering up EVs and come in various types that offer different speeds of charging. Here’s a breakdown of the key aspects of electric car charging stations:
Types of Charging Stations
-
Level 1 Charging:
- Speed: Provides charging through a 120-volt AC plug. A typical Level 1 charger provides about 4-5 miles of range per hour of charging.
- Use Case: Best suited for overnight charging at home or for vehicles that travel shorter distances.
-
Level 2 Charging:
- Speed: Uses a 240-volt plug (like the ones used for heavy household appliances) and can charge an electric car significantly faster than Level 1. Level 2 charging can provide about 10-20 miles of range per hour of charging.
- Use Case: Ideal for home use if you have higher daily driving needs, as well as for public and workplace charging stations.
-
DC Fast Charging (DCFC) or Level 3 Charging:
- Speed: Provides a DC fast charge, significantly speeding up the charging process. It can provide roughly 60-100 miles of range in about 20 minutes of charging, depending on the station and car’s capability.
- Use Case: Best suited for highway rest stops and public charging stations where drivers need to recharge quickly and continue their journey.
Charging Networks
Several companies operate networks of public charging stations, including:
- Tesla Superchargers: Exclusively for Tesla vehicles, these stations are strategically located along major routes to facilitate long-distance travel.
- ChargePoint: Operates one of the largest networks of independently owned charging stations.
- EVgo: Known for its network of fast-charging stations.
- Electrify America: Offers a rapidly expanding network of DC fast chargers across major U.S. highways.
- Blink Charging: Provides a mix of Level 2 and DC fast charging options.
Access and Payment
- Membership and Apps: Many networks require drivers to use an app or membership card to access and use their services. Apps often allow drivers to find nearby stations, check availability, and handle payment.
- Pay-per-use: Some stations allow pay-per-use options, where you can simply pay with a credit card at the station without needing a membership.
- Included With Car Purchase: Some automakers include a certain amount of free charging with the purchase of a new vehicle, particularly for DC fast charging.
Installation at Home
For home charging, particularly for Level 2 chargers, installation typically involves:
- Electrical Requirements: Ensuring your home’s electrical system can handle the additional load.
- Professional Installation: Hiring a qualified electrician to install the charging station.
- Permits: Depending on your location, you may need to obtain a permit from your local government.
Future Developments
The infrastructure for electric car charging stations is rapidly evolving, with continuous improvements in charging technology, speeds, and network availability. Innovations such as battery swap technology, wireless charging, and integration of renewable energy sources are likely to further enhance the EV charging landscape.
Investing in a robust charging infrastructure is crucial for the widespread adoption of electric vehicles, reducing range anxiety, and ensuring that the transition to electric mobility is smooth for consumers.
-
-
LOL. Need to get accustomed to the weather in Wisconsin.
-
Distinguishing between real news and fake news is crucial in today’s information-saturated world, where accurate information is vital for making informed decisions. Here are some strategies and tips to help identify the authenticity of news:
Characteristics of Real News
- Credible Sources: Real news comes from reputable organizations that have a commitment to accuracy and credibility. These organizations follow strict publishing guidelines and are transparent about their sources.
- Fact-checking: Legitimate news outlets rigorously fact-check their information before publishing. Many employ fact-checkers or use fact-checking services.
- Authorship: Genuine articles typically have a clear author or byline, who is a real person with verifiable credentials.
- Corrections: Credible news sources are quick to correct errors and transparent about what has been corrected in their reporting.
- Balance and Fairness: Real news strives for balance and fairness, presenting multiple sides of a story when applicable and refraining from sensationalism.
Characteristics of Fake News
- Dubious Sources: Fake news often originates from questionable sources that lack credibility or are known for spreading misinformation.
- Lack of Evidence: Articles may lack verifiable facts, fail to provide sources, or cite unknown or unreliable entities.
- Emotional Language: Fake news often uses sensational or emotionally charged language to provoke reactions or spread fear or excitement.
- Inconsistency: The story may contain internal inconsistencies, or contradict trusted news reports and verified facts.
- Manipulated Images or Videos: Fake stories may feature photoshopped images or edited videos that do not accurately represent the truth.
How to Verify News
- Check the Source: Investigate the website’s domain and look at other articles published by the source. A credible domain typically indicates a more trustworthy source.
- Cross-verify: Look for the same story on other reputable news sites, especially those with strong journalistic standards.
- Fact-checking Websites: Use established fact-checking sites like Snopes, FactCheck.org, or the International Fact-Checking Network to verify stories.
- Analytical Tools: Tools like Hoaxy or Botometer can help you understand the spread of information and assess the activity around it, such as whether it is being spread by bots.
- Educate Yourself on Media Literacy: Understanding how news is made, the ethics of journalism, and the economic underpinnings of media companies can provide significant insight into the quality of information being presented.
In a digital age where anyone can publish information, the responsibility often falls on the individual to discern the reliability of news. Employing critical thinking, questioning sources, and verifying facts are key skills in navigating the vast amounts of information encountered daily. By being vigilant and educating oneself on media literacy, one can better differentiate between real and fake news.