People are trying to think outside the box. I don't like it out there!

The idea is to send a marketing email to a distribution list from the local board of realtors, to obtain their personal business through the use of our normal referral tools (nothing new that they would get that anyone else can't already get), in the hopes that they will see just how great we are, then they'll want to bring all of their customers to us.

Uh...so you want to market to them something, with a bonus that they will perceive as an incentive for them to do a loan/open an account with us (open checking, get $50, that type of thing), and your goal is to get more referral business from them? Sounds too sketchy to me, and like we're trying to skirt the rules. Other opinions? I just don't like the way it's being presented, and it being stated that it's not a sec. 8 violation because they aren't getting anything, and aren't being asked for a referral. Seems to me that the intent is what matters, but maybe I'm being overzealous, as tends to happen.

IMO, if you are supplying them with anything of value (cash, discounted services, etc.) that you are not offering to all of your potential business clients (either in general, or for a limited time promo that coinicides with the realtor promo), then you are giving them something of value that would be a section 8 violation.

Section 8 is big again (at least on the FDIC's radar).

Thanks for the opinion, glad I'm not completely out in left field with my thinking!