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#2229193 - 01/16/20 04:21 PM Lottery Question
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Good morning!

One of our MLOs asked me a question this morning that I couldn't immediately answer. A local bank gave a few 'coupons' to a real estate agent that are for consumers for $400 reduction in fees for mortgage loans issued at that bank. The real estate agent is going to do a drawing for these coupons for individuals who have come in and met with the realtor to discuss purchasing a home.

While this could be construed as a lottery, I don't think the bank would have any involvement and I don't believe there are lottery restrictions for realtors. Obviously our MLO would like to be able to do something to promote our financial institution.

Does anyone have any thoughts?

Thank you!
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#2229197 - 01/16/20 04:36 PM Re: Lottery Question Skittles
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
You mean besides creating fair lending issues and being a Section 8 issue.

The banker handed the realtor a bunch of $400 bills to distribute in anticipation of referrals.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2229198 - 01/16/20 04:36 PM Re: Lottery Question Skittles
mtngrrl Offline
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mtngrrl
Joined: Mar 2011
Posts: 499
Northern California
Lottery questions aside, isn't that a RESPA Section 8 problem? Something of value given for referral of business?
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