We do not pay referral fees to brokers. Having said that, am I overreacting by having Section 8 concerns in the following senario?

We are doing an interim constr loan brought to us by a broker who does charge a broker fee, which we will disclose. Our lender asked me if there is a problem disclosing two broker fees on the HUD, that another broker gave our submitting broker the customer and they both want to be paid at closing. Of course the siren in my brain says: Duplication of fees, did the other broker do anything to earn the fee, are they splitting or double charging, does the borrower even know about the other broker?
If these are the actual facts, doesn't this scream Section 8?

It very well could. I would be asking for copies of the broker contracts supporting the fees prior to paying the fees out of the settlement transaction.