It appears a flat loan origination fee requirement wasn’t such a good idea after all.  That’s the conclusion the CFPB came to in its proposal issued on August 17 to integrate the Dodd-Frank mortgage loan originator compensation provisions with the existing Regulation Z provisions, and implement Dodd-Frank loan originator requirements. 

We have prepared a legal alert that discusses the proposal and how it differs from the CFPB’s description in May of the issues it was then considering. Comments on the proposal are due by October 16, 2012.