Question: I recently had lunch with a real estate agent to talk about doing some co-marketing. We discussed the potential RESPA concerns and decided to not move forward at this time. At the
Answer: Since the purpose of the lunch was to discuss co-marketing and not as payment for the referral of business, you’re likely okay. Section 8 restricts the payment of anything of value in exchange for the referral of a settlement service. So, if it looks like business is being referred and something of value (e.g. lunch) is being exchanged, a reviewer could infer from all of the circumstances that there is a kickback occurring.
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Published
2019/05/08