I have the same concern, i.e., fee splitting, but the line of business states that we do all the ordinary work that would entitle us to a broker fee (e.g., taking application, obtaining credit report and appraisal, etc.). I am further advised that Party A also does the requisite work in order to earn a broker fee, but it seems to me as though they are simply duplicating the work we have already done. For example, they order another credit report, even though we already did that. I don't know exactly what other duties they perform, but it doesn't seem as though they could really be doing much substantive work of value, since we would already have done basically everything that needed to be done. The line of business is presenting this as though Party B is paying the broker fee to PArty A, and Party A is paying us for the services we rendered, but I can certainly see someone making a successful argument that the broker fee is really being split between us and Party A.