Outside Vendor Paying for Customer Referrals

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Question:

We refer customers to an outside vendor for Merchant Services. The company we deal with has created an incentive program for these referrals. They have submitted one of our employees a check in the amount of $50 for a referral that resulted in a sale. I have read and understand the RESPA implications in regards to referrals in the mortgage lending area, but what about the Deposit side of the bank? Do we allow the employee to accept the check?

Answer:

That would be purely a matter of bank policy on how much you wanted to encourage this practice and whether you wanted the bank to gain $50 as fee income or pass it on to the employee. There are no laws or regulations that would influence the decision either way.

First published on BankersOnline.com 5/22/06