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When a creditor pays MLO compensation directly, what can the borrower also pay to the MLO?

Federal Mortgage Law · 24% of the SAFE exammedium

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Correct answer: Nothing — except for bona fide third-party charges (appraisal, credit report, etc.)

If the creditor compensates the MLO, the borrower cannot pay additional MLO compensation on the same transaction. The only exceptions are bona fide and reasonable third-party charges that go to actual service providers (appraiser, title company, credit bureau) — not to the MLO. This dual compensation prohibition is absolute and cannot be waived by borrower consent or disclosure. The rule ensures borrowers aren't paying hidden costs through both rate (creditor-paid comp) and fees (borrower-paid comp).

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