If the loans/products are truly not subject to RESPA, then Section 8 can't apply. That said, if they also offer settlement services (as defined by RESPA), they could technically be getting some sort of kick back or unearned fee, though it is very difficult to know without digging deeply into the arrangement.
The reason I asked about whether they pay a fair market value to be located in your branch is because I have seen Section 8 violations come from reduced rent in bank branches for a settlement service provider. As Section 8 violations can carry major penalties, it is important to fully understand your relationships with settlement service providers.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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