Thread Starter: Lucy Griffin
Title: Re: Referral fee confusion
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One of the difficulties in analyzing a RESPA issue is that RESPA runs in all directions. For example, both the payor and receiver of a kick-back have violated RESPA. Examiners have often taken the position that if the bank merely collects an illegal fee for one of the settlement service providers, the bank is a participant in the illegal behavior. Who owns the property, who puts forward the money, and who writes the documents is not therefore the deciding factor here. It is whether or not the fee is illegal. If so, everyone involved is guilty.
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