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RESPA Violation Checker

Review common real estate settlement scenarios and identify RESPA violations. Each scenario includes the specific RESPA section reference and detailed explanation.

12scenarios
8violations
6RESPA sections

Check Settlement Scenarios

Select scenarios to reveal whether they violate RESPA.

Kickbacks & Referral Fees

A real estate agent receives a $500 fee from a title company for each buyer referral.

Unearned Fees

A mortgage broker charges a loan processing fee but another company actually performs the processing work.

Affiliated Business

A real estate brokerage refers clients to its affiliated title company without disclosing the ownership relationship.

Escrow Violations

A lender requires an escrow cushion of 4 months of property tax and insurance payments.

Kickbacks & Referral Fees

A lender pays a real estate company for "marketing services" but the payment amount increases based on the number of loans referred.

Seller Title Requirements

A home seller requires the buyer to use a specific title insurance company as a condition of the sale.

Permitted Payments

A title company pays a real estate agent a fair market rent for shared office space.

Permitted Payments

A mortgage company pays its employee loan officers a bonus for each closed loan.

Unearned Fees

Two different settlement service providers each charge the full fee for the same service on a single loan.

Permitted Payments

A listing agent shares their commission with a cooperating buyer's agent through MLS.

Kickbacks & Referral Fees

A home inspector gives a real estate agent gift cards worth $100 each month in exchange for continued referrals.

Affiliated Business

A real estate brokerage refers clients to its affiliated mortgage company, provides written AfBA disclosure, does not require use, and receives only ownership dividends.

Key RESPA Sections for the MLO Exam

Understanding these sections is critical for both exam preparation and compliance in practice.

Section 3 & 4

Disclosures

Requires lenders to provide borrowers with a Good Faith Estimate (now Loan Estimate under TRID) and a HUD-1 Settlement Statement (now Closing Disclosure). Servicers must provide a Servicing Disclosure Statement.

Section 6

Servicing & Escrow

Requires servicers to respond to borrower inquiries within specific timeframes (Qualified Written Requests). Limits escrow account cushions and requires annual escrow analysis statements.

Section 8(a)

Kickbacks & Referral Fees

Prohibits giving or receiving any thing of value for referrals of settlement service business. Penalties include up to $10,000 fine and 1 year imprisonment per violation.

Section 8(b)

Unearned Fees

Prohibits fee-splitting or charging fees for services not actually performed. Each provider may only charge for services they actually render to the consumer.

Section 8(c)

Permitted Payments

Provides safe harbors for employer-employee payments (c)(1), fair-value goods/services (c)(2), cooperative brokerage (c)(3), and properly structured Affiliated Business Arrangements (c)(4).

Section 9

Seller Title Insurance

Prohibits sellers from requiring buyers to purchase title insurance from a specific company. Violation can result in the seller being liable for up to 3x the title insurance charges.

Understanding RESPA Compliance

The Real Estate Settlement Procedures Act (RESPA) was enacted in 1974 to protect consumers during the home buying and mortgage process. It ensures that buyers and borrowers receive timely disclosures about the nature and costs of the settlement process and are protected from abusive practices such as kickbacks and referral fees that unnecessarily increase settlement costs.

Why RESPA Matters for MLOs

RESPA compliance is a core competency tested on the SAFE MLO exam. Federal Laws and Regulations account for 23% of exam questions, with RESPA being one of the most heavily tested topics. As a practicing MLO, understanding RESPA is essential to avoid costly violations that can result in fines, imprisonment, and loss of your license. The CFPB actively enforces RESPA violations and has levied millions in penalties against violators.

TRID Integration

In 2015, the TILA-RESPA Integrated Disclosure (TRID) rule combined the mortgage disclosure requirements of TILA and RESPA into two unified forms: the Loan Estimate (replacing the GFE and initial TIL) and the Closing Disclosure (replacing the HUD-1 and final TIL). TRID rules require the Loan Estimate within 3 business days of application and the Closing Disclosure at least 3 business days before closing.

RESPA Penalties at a Glance

RESPA violations carry serious criminal and civil penalties. Understanding these consequences reinforces why compliance is non-negotiable for mortgage professionals.

$10K

Max fine per violation

1 Year

Max imprisonment

3x

Treble damages (civil)

Frequently Asked Questions

What is RESPA and who does it apply to?
The Real Estate Settlement Procedures Act (RESPA) is a federal law enacted in 1974 that governs the real estate settlement process. It applies to federally related mortgage loans, including most residential mortgage loans. RESPA is enforced by the Consumer Financial Protection Bureau (CFPB) and applies to lenders, mortgage brokers, title companies, real estate agents, and other settlement service providers.
What are the most common RESPA violations?
The most common RESPA violations include Section 8(a) kickbacks and referral fees (paying or receiving compensation for referrals of settlement services), Section 8(b) unearned fees (splitting charges for services not actually performed), and Section 6 escrow violations (requiring excessive escrow deposits). Other violations include failure to provide required disclosures and affiliated business arrangement violations.
What are the penalties for RESPA violations?
RESPA violations can result in significant penalties. Section 8 violations (kickbacks and unearned fees) carry penalties of up to $10,000 in fines and up to 1 year in prison per violation. Borrowers can also file private lawsuits to recover up to 3 times the amount of the kickback or unearned fee, plus attorney fees. Pattern-and-practice violations can result in even larger penalties from the CFPB.
Are marketing service agreements (MSAs) legal under RESPA?
Marketing service agreements are legal under RESPA only if the compensation paid is reasonably related to the fair market value of the marketing services actually provided. If the payments are disguised referral fees — meaning the compensation is based on the volume or value of referrals rather than actual services rendered — the MSA violates RESPA Section 8(a). The CFPB has increased scrutiny of MSAs in recent years.
What is an Affiliated Business Arrangement (AfBA) under RESPA?
An Affiliated Business Arrangement exists when a referring party has an ownership or affiliate relationship with a settlement service provider. RESPA Section 8(c)(4) allows AfBAs provided three conditions are met: (1) disclosure of the affiliation to the consumer, (2) no requirement to use the affiliated provider, and (3) the only thing of value received is a return on ownership interest. Failure to meet any condition is a RESPA violation.

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