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#1953396 - 08/15/14 01:48 PM Section 8 Violation?
Red Raiders Offline
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Compliance Land
Local realtor has asked the bank to sponsor a hole at their annual golf outing where agents and clients will attend.

Section 8 violation or ok?
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Lending Compliance
#1953403 - 08/15/14 01:54 PM Re: Section 8 Violation? Red Raiders
David Dickinson Offline
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Central City, NE
OK if the bank pays a fair market value for the promotion. Realtors and bankers can do business together. What Section 8 is after is business deals that are based on referrals, future business ties, etc. If someone pays fair market value for a thing of value, this is fine.
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#1953416 - 08/15/14 02:12 PM Re: Section 8 Violation? Red Raiders
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Thanks, David. With this being such a hot topic right now I just wanted to be sure that we were ok since this was just one realtor being involved.
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#1959159 - 09/04/14 01:14 PM Re: Section 8 Violation? Red Raiders
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Piggybacking on this because of the similarity....

We have been approached by a realtor to advertise on her Zillow and Trulia websites as a preferred lender. I don't know specifics at this point but I assume the fees are paid directly to the websites (and may offset the amount the realtor pays) and we will have our lender's picture and contact info on the realtor page.

Any issues with this?
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#1959560 - 09/05/14 01:08 PM Re: Section 8 Violation? Red Raiders
Red Raiders Offline
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I have a little bit more information from this. Zillow is saying we can "co-market" with the realtor and pay up to 50% of the agents Zillow monthly fees and be in compliance with RESPA.

We aren't getting 50% of the webpage space so would we be in violation of Section 8 if we paid 50% in the "co-marketing" venture?
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#1959563 - 09/05/14 01:09 PM Re: Section 8 Violation? Red Raiders
Kathleen O. Blanchard Offline

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Well, you said "up to 50%" so why would you pay 50% if you are not getting 50% of the ad? You should pay for what you are receiving, no more, no less.
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#1959591 - 09/05/14 01:44 PM Re: Section 8 Violation? Red Raiders
Red Raiders Offline
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That's my thought as well. Zillow says their attorneys say that a bank can pay 50% of the cost and not violate RESPA. I had never seen 50% referenced in RESPA, only that you pay for what you get so I thought I would throw it out here.

Does anyone have lenders that "co-market" with Zillow (or others like it)?
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#1959612 - 09/05/14 02:03 PM Re: Section 8 Violation? Red Raiders
Kathleen O. Blanchard Offline

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In my opinion, if you pay more than what you receive, the realtor is benefiting.
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HMDA/CRA Training/Consulting/Mapping
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#1959698 - 09/05/14 04:08 PM Re: Section 8 Violation? Red Raiders
rlcarey Online
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Galveston, TX
Zillow says their attorneys say that a bank can pay 50% of the cost and not violate RESPA.

Business Rules:

Rule Number #1: Never, ever trust the other person's attorney.

That also happens to be #2 and #3.

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