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#2257725 - 08/05/21 03:49 PM Section 8 - Compliance Issue?
mnbanker09 Offline
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Joined: Jan 2018
Posts: 95
Our FI is planning to attend an event hosted by a Real Estate Company. Guests at the event are real estate agents.
The monetary 'sponsorship' to participate includes a vendor station, logo in the event program, social media mention, etc. While we are not specifically paying agents directly, the goal is to gain new mortgage business, and the cost to participate does go to the RE company.
There is also discussion about a drawing for a gift card at our vendor table. Is there any RESPA violations or considerations here?

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RESPA
#2257736 - 08/05/21 05:32 PM Re: Section 8 - Compliance Issue? mnbanker09
Adam Witmer Offline
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Adam Witmer, CRCM

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#2257752 - 08/05/21 08:06 PM Re: Section 8 - Compliance Issue? Adam Witmer
mnbanker09 Offline
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Joined: Jan 2018
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Yes, I did review. The gift card drawing I can see is not allowed. What about the attendance in general (and sponsorship?) I feel this also is a violation but want to make sure I've covered my bases before I say - "Sorry, can't do this."

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#2257758 - 08/05/21 08:19 PM Re: Section 8 - Compliance Issue? mnbanker09
Adam Witmer Offline
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It's a bit difficult to say for sure without more details/specifics, but Section 8 is a high-risk area in my mind, and not worth risking it if in doubt.
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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.
www.compliancecohort.com

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#2257760 - 08/05/21 08:48 PM Re: Section 8 - Compliance Issue? mnbanker09
Inspector Offline
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Attending the event probably wouldn't be an issue because that itself wouldn't be a thing of value.

If this involves a real estate company that you are paying to sponsor so you can gain business then you have your Section 8 violation all written up right there. I would stay away from "sponsoring" a single real estate company.

On the other hand, if this is a real estate trade group or something along those lines and all agents from any company can attend and you are paying the same value that other vendors/sponsors are paying to have a booth then you are getting closer to something that could be permissible, but would need to be managed.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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#2257765 - 08/05/21 09:24 PM Re: Section 8 - Compliance Issue? Inspector
mnbanker09 Offline
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Joined: Jan 2018
Posts: 95
Thank you both for the responses, I appreciate the input!

This is an event hosted by one specific RE Company, and there are other vendors that would pay the same as we would. But, at the end of the day, the bank's goal is to gain new business. Looks like I have my answer. Thanks!

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