I have an unusual situation. We have a loan customer that asked one of our loan officers for the name of an insurance agent for hazard insurance on his new home. Our loan officer provided names of 3 agents. The customer chose one of them & told the insurance agent that our LO referred him. As a thank you for the “referral” the insurance agent has kindly provided our LO with a gift basket to present to the customer at loan closing, as though the gift basket came directly from our LO (Bank). There is nothing in or on the basket in reference to the insurance agent.
Is anyone of the opinion there is a RESPA violation? The LO is not directly receiving a thing of value. Our Code of Ethics is not affected due to the value of the gift not exceeding what is allowed under our Code of Ethics Policy.