Question regarding Section 8 or RESPA...

Would you allow your mortgage or lending department to accept a catered lunch paid for by a local title/closing company?

Please explain why you vote yes or no.

I am continually battling my lenders over this topic.

What is the purpose of the catered lunch?

The purpose of the lunch is, while not etched into a stone tablet, obviously for the purpose of generating future referred business.

Thoughts..?

Anyone else out there in the BOL world have an opinion on this topic?

They would then be accepting something of value in exchange for referrals...section 8 IMHO.

ETA: If they were conducting training for you guys...my opinion might be different, but from what you said...or elluded to, that's not the case.

I think you answered your own question when you said the purpose was for referrals.

Thanks. Just needed to hear it from another Compliance guy/gal. I still get strange looks when I tell them they can't accept lunches.

Here is another scenario. A new broker in town is going to have a grand opening soon. He requested a monetary "donation" from the bank for the grand opening - which we will definitely deny. Could the bank give something such as pens, notepads, or even water instead, or would that be considered a thing of value?

My opinion is you are okay with promotional items, including the water, if it contains your logo:

(vi) Normal promotional and educational activities that are not conditioned on the referral of business and that do not involve the defraying of expenses that otherwise would be incurred by persons in a position to refer settlement services or business incident thereto;