I don't know. I don't know what the terms of the "special financing" are. I'm only thinking from the aspect that the builder needs his buyers to have financing. As part of the arrangement to have the bank be a ready source of financing, the builder provides free publicity for the bank. That to me says potential RESPA problem. I just think it needs more work and documentation. Certainly, the bank paying it's share of the marketing costs for its own publicity helps alleviate any potential problems.
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions