What do you think about a title company inviting all bank employees to a customer appreciation picnic at which you can register to win door prizes? With all the talk about RESPA referral violations this seemingly innocent invitation makes me nervous.

Are you telling me that regulators do not have attorney friends and bankers that they socialize with? I have been to many social functions given by title companies, attorney firms, appraisers, etc and have never had a problem with it. And, never even felt guilty about it. It is getting pretty bad when we feel like we cannot socialize with those with whom we work. You may learn at the social event that you like this title office (because of their ethics) and would like to do more business with them. And on another note, you might find out something that would prevent you from recommending them to your applicants.

I would go and have a good time. And, if you win a door prize, good for you.

Its not the socializing that should worry anyone, its the prize. And while RESPA doesn't have an ethics limit as your internal policy may, you should look at this. Are we talking about a gift certificate for the movies, or a trip to the Bahamas? It may be that your employees are not eligable to win.

You should ask who is invited to these events. If it is for all lenders, whether or not they do business with the title agency, then it can be justified as a marketing expense of the title agency that is exempt from Section 8 under an exemption in Section 14 of Regulation X. If the event is only for customers of the the title agency, you could have a problem. It could be inferred that the event paid for by the title agency is a thing of value in return for business obtained by the agency.

It is a Customer appreciation picnic so I would assume it is meant for customers of the title company, and we are customers. The prizes last year were probably in the $20-50 range. This same title company has also delivered lunch (for around 50 people)to the bank around the holidays. I don't know if they do the same for every bank in town.

Around here, gone are the days when the residential lending folks would get breakfast pastries from the Title Companies. Now, only the commercial real estate folks get that kind of stuff. Talk about disparate treatment....!