I agree with Randy. It doesn't appear that you have any kickbacks or unearned fees for a settlement service relating to a federally related mortgage loan. If, somehow, your new Loan Officer started providing kickbacks or unearned fees for mortgage loan referrals, that would, of course, be a problem. But based on their current set-up, I don't see an issue for Section 8 as it has nothing to do with a settlement service for a federally related mortgage loan.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com