12/15/2008
Can the bank pay a teller a referral fee when a first mortgage purchase or refinance closes without fear of a RESPA violation?
11/24/2008
We are considering paying a referral fee for new deposit accounts. Instead of paying the customer or the person making the referral, we'll make a donation to a charity of their choice. Are there any compliance issues with this?
11/10/2008
We have a loan officer who is an active realtor. The loan officer doesn't submit loans where he is the realtor, but goes through another loan officer. Is this a RESPA issue? His realtor business is a separate business from the bank.
11/03/2008
I need to know what we need to do to be in compliance with Reg R Section 218.701. Our employees do receive a referral fee for referring a customer to an investor.
08/18/2008
Regarding RESPA, if the bank wanted to have what might be considered a non-affiliated business arrangement (since the broker has no ties whatsoever to the bank), we understand that the bank is prohibited from paying fees to the broker for anything other than work actually performed, but what about vice versa? If the bank refers applicants to a mortgage broker can the bank charge a flat fee or take a percentage of the fee that the mortgage company charges the customer?
06/02/2008
We have flyers out at a local motorcycle dealership advertising our bank as a possible choice in financing a bike. The dealer has asked if they can receive a referral fee for loans that close at our bank. RESPA states that this is not allowed for dwelling loans, but is acceptable for non-dwelling. How do we list the charge on the loan document?
07/16/2007
Bank A and Mortgage Company B are owned by the same holding company. Bank A has an incentive plan where the employee of Bank A can make a referral to B and A's employee will be paid for that referral. It is paid from A's payroll account, however, A gets the money from the salary of B's originator. There are no affiliated disclosures given at any time during this process. I have read Sections 3500.14 and 15, and have thought so much that I can't think straight about the subject. What are your thoughts?
05/07/2007
Is it a RESPA violation to have a realtors appreciation evening at the bank with food and drink?
04/30/2007
Our bank has been approached by a well-known, large financial services firm that offers reverse mortgage products. This firm would like us to refer customers that may qualify for a reverse mortgage to them. Our loan officers would collect some basic information from the customer, and then send that information to the reverse mortgage provider. That would be the end of our involvement in the transaction. The firm has proposed to pay us a 50 basis points referral fee on the reverse mortgage transaction. My thoughts are that this would be a RESPA Section 8 violation, but this large, well-know financial services provider has indicated that their legal department sees no Section 8 violation for the referral. Any thoughts?
04/23/2007
We are running a mortgage promotion, "Get pre-qualified and get $50." Can we offer the same to real estate agents, "Refer a client for pre-qualification and get $50" or would that be a violation of RESPA?