Does your compensation structure have to be consistent across all lending groups? In other words, can we pay a consistent percentage for each closed loan (same regardless of loan terms) to the mortgage loan officers, but pay a flat fee to retail staff originating home equity loans?

There is no cross over of product offerings between groups, each have their own separate products; however, as proposed, the retail staff may refer and receive a flat compensation fee for referring a customer to a mortgage group's loan product.

I have read through many posts on the topic of compensation rules (226.36), but have not seen anything specific to this question. Please help!

Any thoughts?