FirstBank OnBoarding Manual - Flipbook - Page 94
RESPA REFERENCE FAQ
Can I give gifts (holiday, thank you, etc.) to my favorite realtors?
No. Gifts may not be given as a thank you nor can they be given to a select few. The best way to
thank a realtor is to send them a note and continue to give them great service. Holiday gifts of
minimal cost may be given to all business partners (not just a select few), such as baked goods
or company swag. Same rules apply for receiving gifts; also refer to FirstBank’s Code of Business
Conduct and Ethics in the Vault under Policies & Procedures> FB Financial Corporation.
Can I pay a 50/50 split with a realtor on an advertisement?
Only if the value for its entirety is 50/50 otherwise cost is split pro rata share based on the
work put into the ad.
FirstBank Mortgage will not pay for advertisements that fall under a realtor’s job duties
(house listing, just sold) just as realtor cannot pay for loan officer’s job duties (lending fees,
loan programs).
Can I host a Customer Appreciation Day for past and present clients?
Yes. Hosting an event for past and present borrowers is perfectly acceptable. If you decide to
co-host the event with a realtor or other settlement service providers, then the cost must be
split evenly. Document total costs and what everyone paid.
A realtor has asked me to help with a continuing education course, can I do this?
Depends. Continuing education credits is a cost that realtors must incur themselves. FirstBank
Mortgage will not in any way contribute to the cost of the course / credits. However, if an
LO wants to sponsor a class by providing food and market themselves in person, then this is
acceptable. The sponsorship cannot defray costs for the host or the realtors taking the course.
We did this same advertising / networking last year,
so I should be good for this year?
No, not all requests may have been approved through the proper channels in the previous
year. In addition, there might be minor changes to the ad / event from the previous year,
new policy changes, and / or new regulatory guidance has been issued that could impact
compliance.
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Onboarding Manual
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