Gifts are a concern, and not only during the holiday season. The recently issued FAQs allow allows “normal promotional and educational activities” directed to a referral source if the activities meet two conditions:
The activities are not conditioned on referral of business; and
The activities do not involve defraying expenses that otherwise would be incurred by the referral source.
Learn more about Jack Holzknecht’s RESPA – Section 8 Unearned Fees and Kickbacks Violations webinar.