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Ethics & Fraudmedium17% of exam

An MLO discovers that a competitor is offering borrowers cash payments outside of closing to choose their company over others. The MLO's manager suggests they should start offering similar incentives to remain competitive. What should the MLO do?

Correct Answer

C) Refuse to participate in such practices as they likely violate RESPA

Cash payments to borrowers for choosing a particular lender likely violate RESPA's anti-kickback provisions. MLOs must refuse to participate in potentially illegal practices regardless of competitive pressure or management direction.

Answer Options
A
Follow the manager's suggestion to remain competitive in the market
B
Offer non-cash incentives instead to avoid direct cash payments
C
Refuse to participate in such practices as they likely violate RESPA
D
Report the competitor to state regulators but continue normal business practices

Why This Is the Correct Answer

Cash payments to borrowers for choosing a particular lender likely violate RESPA's anti-kickback provisions. MLOs must refuse to participate in potentially illegal practices regardless of competitive pressure or management direction.

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