Skip to content
 

Ad Featuring Prominent Bank Customer

Answered by: 
John Burnett
Dan Persfull

Question: 
Our commercial lenders want to place an ad that mentions a prominent bank customer in the residential construction industry in an ad. This customer is being mentioned in return for marketing efforts in increasing their volume of business with the bank. Are there any regulatory issues of concern?
Answer: 

Answer by John Burnett:I'd certainly be concerned about RESPA. The lenders propose to provide the customer, who is involved in the settlement of residential real estate transactions, something of value (advertising exposure), for what appears to be no consideration. I get concerned about RESPA violations whenever someone gets something for nothing and the parties are both participants in the real estate settlement.

Answer: 

Answer by Dan Persfull:Sure sounds like something of value is being given to the builder in anticipation of referrals. Definitely a Sec 8 problem IMO.

First published on BankersOnline.com 11/19/07

First published on 11/19/2007

Filed under: 
Operations
Filed under operations as: 
Estate
RESPA

Report a problem with this page

Search Topics