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A real estate brokerage creates a subsidiary mortgage company where the same employees work for both entities. Borrowers who use the mortgage subsidiary receive a $500 credit toward closing costs. Under RESPA, this arrangement is:

Correct Answer

A) Prohibited as an illegal kickback under Section 8(a)

This arrangement violates RESPA Section 8(a) because the $500 credit constitutes a thing of value given for the referral of settlement service business. The fact that the entities are affiliated does not exempt them from the prohibition against kickbacks, and the credit incentivizes borrowers to use the affiliated service.

Answer Options
A
Prohibited as an illegal kickback under Section 8(a)
B
Allowed if proper AfBA disclosures are provided
C
Permitted only if the credit is disclosed on the Loan Estimate
D
Acceptable as long as the entities maintain separate business licenses

Why This Is the Correct Answer

This arrangement violates RESPA Section 8(a) because the $500 credit constitutes a thing of value given for the referral of settlement service business. The fact that the entities are affiliated does not exempt them from the prohibition against kickbacks, and the credit incentivizes borrowers to use the affiliated service.

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