Answer:
There are no red flags of which I am aware. Just be certain to gather address and TIN information for IRS purposes should any individual receive $600 or more from this promotion, combined with others you may offer, during the calendar year. The area of concern is in RESPA related loans and referral fees to third parties. This is not the case in the scenario you present.
First published on BankersOnline.com 8/10/09