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A title company offers a 'loyalty program' where real estate agents earn points for each referral, redeemable for gift cards after 10 referrals. The title company argues this is not a per-transaction payment. Under RESPA, this program is:

Correct Answer

C) Prohibited as it provides value in exchange for referrals

RESPA Section 8(a) prohibits giving anything of value for referrals of settlement service business. The loyalty program structure does not avoid this prohibition because the points system still provides value contingent upon referrals, regardless of the delayed or accumulated nature of the reward.

Answer Options
A
Permitted because payments are not made for each individual referral
B
Allowed if the gift card value is under $25 per referral
C
Prohibited as it provides value in exchange for referrals
D
Acceptable if disclosed to all borrowers in writing

Why This Is the Correct Answer

RESPA Section 8(a) prohibits giving anything of value for referrals of settlement service business. The loyalty program structure does not avoid this prohibition because the points system still provides value contingent upon referrals, regardless of the delayed or accumulated nature of the reward.

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