FirstBank OnBoarding Manual - Flipbook - Page 95
RESPA REFERENCE FAQ
I have been asked to sponsor a realtor’s event.
There are multiple lenders that are sponsoring, is that ok?
Depends on the total cost of the event for the realtor. If multiple lenders are sponsoring and
their combined costs cover the entire or a majority of the event, this is a direct violation. Each
lender must pay fair market value for their contribution that does not defray realtor’s costs.
Same rules apply for FBM events with industry sponsors.
One of my realtors has offered to create and distribute
a co-branded advertisement free of charge.
While that is a nice gesture, we cannot accept free advertisement. There are costs in design,
print and delivery, if applicable, that must be split on pro rata share. Also, all advertisements
created must meet FirstBank Mortgage’s advertising and compliance standards and go
through the approval process.
D OS
•
•
D O N ’ TS
Know all parties involved and what everybody
is contributing, i.e., other sponsors, are
sponsorships equal or categorized by tiers, etc.
•
Give or accept cash payments/gifts.
•
Endorse business partners.
Pay third party vendors, where applicable, for
advertising rather than to another settlement
service provider.
•
Show or infer exclusivity.
•
Defray settlement service provider
costs that would otherwise be incurred
within the normal course of business.
•
Attend the event you contribute to.
•
Remove ‘referral partner’ and
‘preferred lender’ out of your vocabulary.
•
Document all transactions / invoices
and its details on what the payment was for.
Sources:
12 CFR Part 1024.14 - Real Estate Procedures Act
National Association of Realtors - Following RESPA Rules: https://www.nar.
realtor/ae/manage-your-association/association-policy/following-respa-rules
The Mortgage Banker Magazine Volume 7, Issue 2
94
Onboarding Manual
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