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#2202658 - 01/10/19 09:02 PM Joint marketing in broker relationship -RESPA?
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Hello Everyone,

We broker all our mortgage applications out to a large national mortgage lender (we dont do traditional financing in house)

Our Marketing department would like to mention them in our ads - does anyone see this as a section 8 issue?

We are in a contractual agreement to provide referrals (applications) on a fee basis, would adding there name and/or logo to a flyer create any potential RESPA section 8 issues?

As always, any advice is greatly appreciated.

Thank you!
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2202684 - 01/10/19 10:37 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
BUmp
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#2202713 - 01/11/19 03:28 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
To mention them, you would need their permission. I would start there.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2202737 - 01/11/19 04:48 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Already have received it and had discussions with them. They seem to be ok with it, just double checking for potential section 8 issues.

Any concerns Randy? (and thank you by the way)
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2202754 - 01/11/19 05:13 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
I don't have that many concerns - except I surely hope you did not mean this literally: We are in a contractual agreement to provide referrals (applications) on a fee basis,
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2202786 - 01/11/19 08:42 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Not literally.. poorly typed. We accept the applications and send them to the lender for decision, disclosure, etc.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2202818 - 01/12/19 04:44 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
And you do at least five or more compensable services in additional to sending the application to the lender and the fee is reasonable, I assume?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2202962 - 01/14/19 10:38 PM Re: Joint marketing in broker relationship -RESPA? JC (Darth HMDA)
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Correct!
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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