Our bank would like to give current customers $25 cash to refer a friend. We have been advised that those clients must then receive a 1099 at year end for the "gift." I've seen other banks do this successfully so are they all issuing a 1099?
As part of an employee loan referral program, is it permissible to offer friends and families of employees an incentive? For example, if a borrower brings in a referral card they received from an employee, can we offer the borrower $50 for getting their loan through us?
We are contemplating purchasing a residential loan from another institution when it closes. This means that we would "table fund" at the loan closing. What compliance issues do I need to be concerned about?
We want to increase our market share of commercial accounts. If we pay a referral fee for a business deposit account, are there compliance restrictions?
Is it a Section 8 violation to pay bank employees a referral commission for secondary market mortgage loan referrals on closed loans?
Would it be a violation of RESPA's anti-kickback provisions to pay an existing customer an incentive fee for referring a friend or family member to the bank for a mortgage loan?
If a bank were to have a Regulation B violation by requiring the signature of a non-participating spouse as a guarantor in a secured commercial business loan, do they really have that guarantor or would that signature be considered invalid? Would they be able to use that signature to get other documents, such as deeds of trust and or a release of claims from the same nonparticipating spouse, or is that just more violations of Regulation B? What sort of consequences would the bank be facing? Do you know of a Regulation B expert consultant I could speak to or consider hiring?
If we process, underwrite and close loans in our name, but pay the third party originator a referral fee and disclose it on the Good Faith Estimate is this a violation of RESPA?
Is it permissible to pay bank employees for mortgage loan referrals to a mortgage affiliate of the bank? The referral would be paid by the bank to bank employees for generating the businesses. We would like to establish an incentive program based on the loan amount for closed mortgage business only. The payment would be calculated based on the loan amount and would consist of two tiers. Is this in compliance with RESPA? Would we need to complete an Affiliated Business Arrangement Disclosure Statement?
Are we in violation of any regulation if the bank purchases fruit baskets from the local FFA chapter and gives them as gifts to our top loan customers at the end of the year?