CL
ClearLife
MLO Recruiting
Two recruiting paths · same comp engine

Outside Contractor vs Employee

Both Clear.Life recruiting paths share the comp engine, the two-tier model, and the registration platform. They differ on legal classification, breach mechanics, and (for employees) CFPB MLO Compensation Rule defensibility.

Document & Legal Status
Shared by both paths
  • ·Same Clear.Life Platform registration + Sponsor Handle
  • ·Same Direct + Indirect Tier compensation model
  • ·Same comp engine, contract-grade math (INV-MATH-006: comp level ratchet)

Outside Contractor

1099
  • ·Standalone Recruiting Agreement (1099)
  • ·Self-employment income (1099-NEC)
  • ·Independent-contractor relationship — no employment ties

Employee Recruiter

W-2
  • ·Recruiting Addendum + LO/Manager Compensation Agreement (W-2)
  • ·Comp paid as bonus on W-2 (CFPB-defensible per [Employee §48])
  • ·At-will employment with Clear Home Loans
Compensation & Payment
Shared by both paths
  • ·Two-Tier model: Direct (your direct recruits) + Indirect (everyone deeper, via Δ = level(P) − level(D))
  • ·Max100 Rate publishes every 6 months [Both §16, §32]
  • ·10 Comp Levels — COMP 10 (10% × Max100) through MAX100 at $900M CQV
  • ·Monthly payment, 45 days after the production month [Both §36]

Outside Contractor

1099
  • ·Paid as Recruiter Fee (commission-style)
  • ·Continues after contract ends if no breach declared
  • ·Disbursed via 1099 ACH (Routable)

Employee Recruiter

W-2
  • ·Paid as Bonus through Clear Home Loans payroll
  • ·Forfeits any payments not yet due at separation [Employee §48]
  • ·Bonus framing matches CFPB MLO Compensation Rule defensibility
Termination & Breach
Shared by both paths
  • ·Same breach triggers: Employment by another lender, breach of good faith, disparaging statements [Both §52 / §49]
  • ·Same 12-month non-solicitation window after termination
  • ·Same TPC two-person-confirm gate before any breach declaration ([Ch.7 §1.2])
  • ·Rescission flow with shadow-comp preview — admin can true up partial / full / zero (Bill B3)

Outside Contractor

1099
  • ·Voluntary terminate: ongoing comp on prior referrals continues to accrue
  • ·Breach: ongoing comp halts immediately; clawback may apply [Contractor §39]
  • ·Held below-threshold + lapsed balances released on voluntary exit (Bill Q1)

Employee Recruiter

W-2
  • ·Voluntary separation: payments not yet due forfeit [Employee §48]
  • ·Breach: same halt + clawback as contractor [Employee §38]
  • ·At-will employment — termination requires no cause
Registration & Platform
Shared by both paths
  • ·Same Annual Administrative Fee: $99 BASIC or $299 COMBINED (incl. mailbox) [Both §23(c)]
  • ·Same 30-day signing window after registration [Both §28]
  • ·Same 12-month registration expiry if inactive [Both §46 / §44]
  • ·Same comp-funded renewal mechanic — fee deducts from accrued comp before disbursement (Bill B2)
  • ·Same Confidentiality + audit-log retention

Outside Contractor

1099
  • ·NMLS ID optional
  • ·1099-NEC issued annually

Employee Recruiter

W-2
  • ·NMLS ID required for EMPLOYEE_MLO
  • ·W-2 wages reported through CHL payroll system
  • ·Manager-tier comp via separate Manager Compensation Agreement
Want to see the math? Try the public earnings calculator with your own assumptions.

Section citations refer to the canonical contract documents maintained at dna/01-domain-entities-and-data-model.md.

Both agreements include binding confidentiality provisions on document receipt. Consult outside counsel for guidance specific to your situation.