U.S. Bank has joined forces with the U.S. Hispanic Chamber of Commerce and the Arizona Hispanic Chamber of Commerce in a program aimed at bringing funding to the Hispanic community. U.S.
I am a loan officer in at a mortgage broker office. Can I mail cards to my sphere of influence offering 2 tickets on the Napa Valley Wine Train for referring 2 parties to me that result in closed loans? Is that legal?
We would like to begin a refer a friend program where we would give a $50 gas card to any customer that refers a friend to open up a checking account. Would this be subject to IRS reporting, and if so on a 1099-INT or a 1099-MISC? Also, are there any privacy issues with doing this?
Our marketing group came up with a new ad where we would mail CPAs a free 50 minute phone card. It is supposed to get our name out to this group as a referral source. The ad says (among other things) "Be sure to recommend xxx Bank to any of your clients who would benefit from our personalized approach to banking." If this ad is universal across the board to our CPAs and not tied specifically a consumer real estate transaction, could we have a RESPA Section 8 issue, if a CPA refers someone to the bank for a Home Equity Loan, or a personal residential mortgage?
Can I offer a client a gift certificate of up to $500 good at the business they work at, for refinancing with my company?
Is it a RESPA violation for mortgage brokerage firms to offer gifts such as a vacation package to real estate agents in exchange for home loan referrals?
Is it a RESPA violation to offer consumers a referral fee for referring a customer to a Bank for a home equity line of credit?
We would like to start a customer reward program where we pay existing customers $10 for every new customer they refer to us. Are there any regulatory or compliance isssues that this would raise?
What marketing methods have you found to be most effective in building a loyal referral source from realtors?
We are considering a relationship with a non-affiliated real estate broker. Here's how it works: If a homebuyer purchases a home through this broker and then finances the loan with us, the customer will get a $500 reduction in real estate commissions from the broker and a $500 credit from us toward our typical closing costs. We are one of nine banks that are being offered this opportunity brought to us by the broker. No money changes hands between us and the broker. If the buyer does not use one of the nine banks, they don't get the commission reduction, and if they don't buy their home through that broker, we will not give a discount. Do we have a potential violation of Section 8 of RESPA if we participate? The definition of "thing of value" includes the "the opportunity to participate in a money-making program." A referral "includes any oral or written action directed to a person which has the effect of affirmatively influencing the selection by any person of a provider of a settlement service or business incident to or part of a settlement service when such person will pay for such settlement service or business incident thereto or pay a charge attributable in whole or in part to such settlement service or business." It seems that we may meet both of these definitions, but I'm not sure if I'm misinterpreting or just plain missing some important exclusions.