One in ten of our clients is a mortgage lender.
More than twenty-five mortgage lenders, every one of them between fifty and a thousand employees. That is the deepest single concentration in our book, and it is why this page can tell you what breaks in a lending company’s benefits program before you tell us.
Be clear about where the depth is not. It sits in the two middle size bands. Below fifty and above a thousand we will still help you, but we will not claim to have seen your exact situation twenty-five times.
Commission pay breaks the test everyone else passes by default.
What Is Actually True in Mortgage Lending
- Commission-heavy pay breaks the rate-of-pay affordability safe harbor — there is no reliable hourly or salary figure to test against, so the safe harbor has to be chosen deliberately and documented.
- Headcount swings with rate cycles. A hiring year and a contraction year change applicable-large-employer status, and it is measured on the prior calendar year, so the obligation always lands late.
- Licensing across states scatters a modest headcount into markets where one carrier’s network is strong and another’s is not.
- The highest earners are a large, well-defined group, which is what makes Section 105(h) testing bite here once a plan is self-funded.
What CFH Does About It
- Tests affordability on the safe harbor that fits a commission structure, and writes down why it was chosen.
- Flags the applicable-large-employer threshold in the year you cross it, not the year it bites.
- Checks network strength in the states you are licensed in, not just the one you are headquartered in.
- Runs 105(h) before a funding change is adopted rather than after.
Four sizes, four different problems.
Find your headcount. What changes at that size in this industry, and what we do about it.
Rates are community-rated and age-banded, so the renewal moves with who joined and who left, not with how the year went. There is no employer mandate yet, but COBRA obligations start at twenty employees.
What we do about it: Prices the small-group market properly rather than accepting the incumbent’s renewal, and sets up the notice calendar before it is a problem.
You are an applicable large employer and 1095-C reporting begins, measured on the prior calendar year. This is where commission pay breaks the rate-of-pay safe harbor.
What we do about it: Tests affordability on the safe harbor that actually fits a commission-heavy pay structure, and documents why it was chosen.
Self-funding and level-funding become real options and your claims experience is finally credible. Self-funding switches on Section 105(h) testing, which matters more here than in most industries.
What we do about it: Models funding against your own claims, and tests the design for 105(h) before it is adopted rather than after.
Licensing across states means employees in markets where your carrier’s network is weakest, and carve-outs mean several sets of documents, disclosures and filings rather than one.
What we do about it: Runs the vendor stack as one program, and brings a documented process the risk committee can actually read.
Lenders and finance teams we serve, one page each.
Consumer Finance and Auto Lender
Group health benefits for Michigan consumer finance and auto lenders: branch staff, servicing teams, and commission pay.
Bank and credit union employee benefits in Michigan: branches, back office and executives
How Michigan banks and credit unions can plan benefits across branches, operations and executives, including plan documents, reporting and retention.
Real Estate and Rental and Leasing
Title and Settlement Company
Employee benefits for Michigan title and settlement companies: closers, escrow officers, examiners and processors tied to the mortgage cycle.
Mortgage Branch Acquisition and Loan Officer Lift-Out
Employee benefits for Michigan mortgage companies adding a branch or lifting out a loan officer team: onboarding, waiting periods and plan design.
Wholesale and Correspondent Mortgage Lender
Employee benefits for Michigan wholesale and correspondent mortgage lenders: account executives, underwriters, lock desk and secondary marketing teams.
The three things employers in this sector ask us first.
Our loan officers are commission-only — how is affordability even calculated?
Not on rate of pay, which needs a reliable hourly or salary figure you do not have. We select and document a different safe harbor that fits commission pay. The usual alternatives are the W-2 safe harbor, which tests against the wages on each employee’s W-2 after the year ends, and the federal poverty line safe harbor, which ignores pay entirely and is the simplest to prove.
We doubled and then halved in two years. What does that do to our reporting?
Applicable-large-employer status is measured on the prior calendar year, so a hiring year creates obligations in the contraction year that follows. We flag it in the year you cross, not the year it bites. COBRA also follows the prior year’s count, so the same lag applies there. Keep hours and offer records month by month through the downturn, because that year’s 1095-C forms are built from them.
We are licensed in nine states and insured in one. Is that a problem?
It is if the carrier’s network is thin where your people live. We check adequacy in every state you are licensed in, not only where you are headquartered. We map where employees actually live, which for remote loan officers can differ from the branch address. Where the network is thin, the options include a national network plan or a separate plan for those states.
Related guides.
Mortgage Lenders and Financial Services
Benefits when pay is commission-based and headcount swings.
Remote and Hybrid Mortgage Loan Officer
Many loan officers now work from home or in a hybrid mode, often in more than one state.
Mortgage Servicing and Processing Center
Servicing and processing centers handle payments, underwriting, closing, and customer care.
Non-Bank Mortgage Company Growth and
Non-bank lenders can grow quickly, adding offices and loan officers.
Mortgage Broker and Small Lender
Small mortgage brokers and lenders have a few loan officers, processors, and an owner involved in every decision.
ICHRA for Mortgage Lenders
An individual coverage HRA lets a mortgage lender set allowances by permitted class, such as salaried and hourly or full-time and…
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
COBRA Continuation Coverage (29 U.S.C. 1161)
Requires many group health plans to offer temporary continuation coverage after a qualifying event.
ACA Reporting (26 U.S.C. 6056)
The statute behind employer reporting of offers of coverage on Forms 1094-C and 1095-C.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →