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#2077317 - 05/05/16 08:01 PM How to Aggressively Market w/ Section 8 in Mind
Norman Paperman Offline
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Norman Paperman
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This would be a great thread/topic for discussion. I think most of us are in the same boat in that we have a perpetual fight between supporting the bank's mortgage marketing efforts and not knowing where the line is drawn with regards to Section 8 ambiguity.

A solid discussion on how to successfully market a mortgage operation, with Section 8 compliance in mind would be of great value.

If anyone has examples of their marketing strategy that are innovative, yet Section 8 compliant, let's hear it.
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#2077319 - 05/05/16 08:08 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
rlcarey Online
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rlcarey
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Galveston, TX
You go out and shake every persons hand that you meet and tell them to come and see you next time they need a mortgage loan. smile

Can't get any safer than that.
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#2077968 - 05/10/16 08:35 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
MyOhMyWeComply Offline
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Joined: Sep 2015
Posts: 114
Texas
We are kicking around many ideas: The closest one we are looking at is described below and I would appreciate any thoughts and comments.

We are looking at networking with a local broker firm. We would tell our customers about the brokerage firm and let them know that they offer a lower brokerage fee if financed through us. We would already be doing the "pre-approval" for these customers and would offer it as a "customer perk"...

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#2080199 - 05/24/16 09:51 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
What do you think about taking a bottle of wine to a realtor after a loan they brought to the bank closes, in appreciation for the completed transaction? Another fine, RESPA line, and of course you can construe it out to thanking them so they'll bring you future business. Unless maybe it's Boone's Farm or something. But really, what do you think about this "thank you" approach?

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#2080200 - 05/24/16 10:05 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Inspector Offline
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Joined: Apr 2016
Posts: 283
Wyogirl - That is a pretty clear cut RESPA Section 8 violation. Try a nice card and forego the bottle (or box) of wine.
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#2080204 - 05/24/16 10:16 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
Ha ha, that doesn't make sense, a card costs more than a cheap bottle of wine! LOL!

Now, put our bank logo on that same bottle of wine...

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#2080206 - 05/24/16 10:26 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Inspector Offline
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Joined: Apr 2016
Posts: 283
Well blame Hallmark for that, sounds like you spend more on cards than I do. You could try that argument on your examiners, "but the wine we give them is terrible". Let me know how that plays out smile

All joking aside, its giving a thing of a value for a referral. I don't think the logo is going to make any difference.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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#2080209 - 05/24/16 10:43 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
I know the rule, and do take it very seriously. A thing of value is a thing of value and both a card and a bottle of wine are things of value. No arguments. Unfortunately my marketing department hates me after 20 odd years of telling them no, so I simply must have fun with it. And, we seriously do have promotional bottles of wine, LOL!!!!!

I see you are a new poster, welcome aboard.

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#2080805 - 05/27/16 01:21 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Island Dreaming Offline
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Joined: May 2009
Posts: 231
midwest
I don't have any advice but will share something I recently saw posted on social media. A real estate agent posted a picture of their office enjoying a gift basket on Cinco de Mayo. It included chips, salsa and all the makings for margaritas. They were thanking one of the local mortgage loan officers for the gift. The post included the mlo's name, nmls number and employer.

As a compliance officer - I cringed - but was glad it wasn't one of my mlo's!
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#2083899 - 06/16/16 10:02 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
AmieeM Offline
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Joined: Jan 2016
Posts: 35
Is it a violation of RESPA section 8 if an LO invited a realtor to a basketball game? The LO would be going with the realtor. thoughts?

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#2083915 - 06/17/16 01:24 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Ticket to ball game - something of value.

LO taking Realtor - LO is doing so in anticipation of, or for referrals from the Realtor.


Sec. 8 - yes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2083933 - 06/17/16 02:15 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
MyOhMyWeComply Offline
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Joined: Sep 2015
Posts: 114
Texas
I agree with Dan but I want to ask the question with a twist and see if feelings are same...

LO invited a Realtor, who is his friend prior to him becoming a LO, to a basketball game.... LO received tickets as a give a way from local radio station.....

Would this be a violation?

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#2083936 - 06/17/16 02:22 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Docs Offline
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Posts: 241
The ticket is still a thing of value. Does not matter how the giver obtained it.
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#2084071 - 06/17/16 07:24 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
As Docs said it is still a thing of value, but if the Realtor and LO are truly friends outside of the "business" relationship then I would not consider this a Sec. 8 issue. Although there is a fine line that has to be watched in these situations. IOWs the LO could not turn in an expense report to recoup costs of concessions, etc.

The purpose of Sec. 8 is to prevent "bribery". I would not consider taking a friend to a ballgame a bribe.

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#2084083 - 06/17/16 07:47 PM Re: How to Aggressively Market w/ Section 8 in Mind Norman Paperman
AmieeM Offline
Junior Member
Joined: Jan 2016
Posts: 35
Thank you!! I tend to be conservative- and not naive either, and I just don't like it. The LO can tell me all they want that it's not for a referral, but we all know it is!
We just hired a group of green LO's- we are doing a 2 month classroom style training with them. When I spoke to them about RESPA Section 8 that raised A LOT of questions for them. My initial reaction and gut says NO, but I also tend to air on the conservative side too so I wanted to get your opinions as well.

Thanks a bunch! smile

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