Loan Originator Compensation Disclosure

Statutory Basis

This Loan Originator Compensation Disclosure is provided in connection with Regulation Z § 1026.36, which implements the Truth in Lending Act, 15 U.S.C. § 1601, and the loan-originator compensation rules adopted by the Consumer Financial Protection Bureau and predecessor agencies.

Two Permissible Sources of Compensation

Under Regulation Z § 1026.36(d)(2), a mortgage loan originator may receive compensation in connection with a residential mortgage loan from only one of the following sources for any single transaction:

1. The creditor (the lender funding the loan); or
2. The consumer (the borrower).

If the loan originator receives any compensation directly from the consumer for a particular transaction, neither the loan originator nor any other person may receive compensation from another person in connection with the same transaction (except as expressly permitted under § 1026.36(d)(2)(ii) for specified transferred upfront points or fees).

How Marcus Naulin Is Compensated

Lender-Paid Compensation. When a wholesale lender pays the originator, the amount is set in advance under a written compensation agreement and does not vary based on the terms of the transaction other than the amount of credit extended. The borrower does not pay the originator's compensation directly; lender-paid compensation is reflected in the interest rate offered.

Borrower-Paid Compensation. When the borrower elects to pay the originator directly, the compensation amount is disclosed at application on the Loan Estimate and on the Closing Disclosure as "Origination Charges." In a borrower-paid transaction, the originator may not also receive compensation from any other person.

Anti-Steering

Under Regulation Z § 1026.36(e), a mortgage loan originator may not steer a consumer to consummate a transaction that the consumer cannot afford or that is not in the consumer's interest in order to increase the originator's compensation. We comply with the anti-steering safe harbor by presenting loan options that include: (i) the loan with the lowest interest rate; (ii) the loan with the lowest interest rate without negative amortization, prepayment penalty, balloon payment, demand feature, shared-equity, or shared-appreciation; and (iii) the loan with the lowest total dollar amount of discount points, origination points, and origination fees, where applicable.

Comparison Choices

You have the right to compare offers from multiple loan originators and lenders. Loan Estimate forms allow direct comparison of finance charges, annual percentage rate, origination charges, services, lender credits, and cash to close. We encourage all consumers to obtain multiple Loan Estimates.

Pricing Concessions and Tolerance

Tolerance and good-faith requirements under Regulation X § 1024.7 govern any change between Loan Estimate and Closing Disclosure. We will provide a revised Loan Estimate within three (3) business days where a change-of-circumstance occurs, and will absorb tolerance-violation amounts where required.

Fee Schedule on Request

You may request a fee schedule for non-lender services by emailing contact@marcusnaulin.com. Fees are also itemized on the Loan Estimate and Closing Disclosure.

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