FirstBank OnBoarding Manual - Flipbook - Page 93
RESPA REFERENCE FAQ
What is a settlement service provider?
Any service provided in connection with a prospective or actual settlement,
including, but not limited to, any one or more of the following:
These are NOT settlement
service providers:
•
Real Estate Brokers and Agents
•
Mortgage Bankers and Mortgage Brokers
•
Title Companies and Title Agents
•
Home Warranty Companies
•
Moving Companies
•
Hazard Insurance Agents
•
Gardeners
•
Appraisers
•
Painters
•
Flood and Tax Service Providers
•
Decorating Companies
•
Home and Pest Inspectors
•
Home Improvement Contractors
What is a thing of value?
This list is non-exhaustive and must be reviewed by Compliance.
•
Monies, things, discounts, salaries,
commissions, fees, duplicate payments of
a charge, stock, dividends, distributions
of partnership profits, franchise royalties,
credit representing monies that may be
paid at a future date;
•
Services and products of all types at
special, discounted or free rates;
•
Sales or rentals at special prices or rates;
•
Lease or rental payments based in whole or
in part on the amount of business referred;
•
The opportunity to participate in a
money-making program;
•
Trips and payment of another person’s
expenses;
•
Retained or increased earnings;
•
•
Increased equity in a parent
or subsidiary entity;
Reduction in credit against an existing
obligation;
•
Meals; or
•
Special bank deposits or accounts;
•
•
Special or unusual banking terms;
Joint advertising between settlement
service providers.
What is the dollar threshold for a thing of value?
There is no set dollar amount for a thing of value, as value is not limited to money but also a
benefit. Two things to consider: the purpose / intent of the thing of value (Does it defray costs
to another settlement service providers normal course of business? Is it in hopes of referrals?)
and is it reasonably priced?
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Onboarding Manual
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