We are looking at a referral agreement where the bank will send customers looking for secondary market products (fixed rate loans, VA, FHA, etc.) to a mortgage broker, and in return, the bank will get a referral fee of 1% of the loan origination amount. The bank collects certain information from the customer up front, but the underwriting and servicing takes place with the mortgage broker.
What compliance issues does the bank need to take into consideration on this type of arrangement?