One of our lenders would like to use the bank conference room for a meeting with the board of realtors. Would that be a RESPA violation?

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I know it is a super particular question. It would not be anything more than a meeting space, no food or refreshments are provided etc etc.

I am thinking that it could be. While it would be determined that there would be no referrals, we can't guarantee that they would not go out and say we use bank so and so for meeting space etc. They are not paying for the space, but they don't normally pay for space at their meetings, they are usually held at a cramped office somewhere however the desire is for more space. My thought is that if they are cramped and looking for an alternative space, they would have to pay for it, and if they don't pay for it here, that could be looked at as a kickback. Am I off the rails on this?

This would be an ongoing meeting that is held regularly, not a one time meeting with this lender (which was how I read the first question)?

I personally would prefer they find space elsewhere and not at a bank (or anywhere else that could cause a RESPA referral issue.)

If you routinely offer (without charge) the bank's conference room to all kinds of community groups, that improves your defensive argument that this accommodation is not a "thing of value." Since this appears to be an offensive decision (i.e., you can still say "no"), I'm with Kathleen. It's a VERY poor business decision to flirt with a Section 8 violation. Have you asked your lender how s/he looks in blaze orange?

Thank you both for posting

They do want to make it an ongoing meeting. It was originally a one off during non banking hours but morphed into this. We originally said no to the one off request due to RESPA and liability concerns with having folks in during non banking hours. Now they have come back and asked if they could do regular meetings because of the lack of space they currently have. My thought is don't mess with it, but I am getting some serious push back.

We do offer up space to some civic and social groups on a very limited basis. To be honest, I do not recall the last time...they probably don't ask me though so it could be more than I think. But my thought is that those are not mortgage related organizations.