No question about it. This is a clear violation of RESPA Section 8. In fact,
FIL-103-99 [November 17, 1999] entitled "Potential Violations of Section 8 of the Real Estate Settlement Procedures Act" gives this example as a thing of value (which can't be given for a referral of a RESPA covered loan):
• “Thing of value,” also broadly defined, includes all types of compensation such as monies, discounts, salaries, commissions, fees, and preferential bank rates.
HUD has described the opportunity to win a prize as a thing of value. For example, a bank cannot enter real estate agents in a pool to win a trip to Hawaii if a certain number of customers are referred to the bank for a mortgage loan.