[MBT_Compliance1]

1. Would a Lunch & Learn Educational Event for Realtors be permissible if opened to all Realtors in the area?

2. The Bank has an Affiliated Business Arrangement with a percentage ownership in a title insurance agency. If disclosed on the AfBA, is it permissible or not to require the use of this provider?

Topic

[rcooper]

1) This could be fine depending on the circumstances. Section 8 of RESPA permits educational activities that are not conditioned on the referral of business and that do not involve the defraying of expenses that otherwise would be incurred by persons in a position to refer settlement services or business. If you are subsidizing the cost they would normally incur for continuing education is would be considered a referral fee. (1024.14(g)(1)(vi))

2) You can’t require the borrower to use any particular provider except an attorney, credit reporting agency, or real estate appraiser. (1024.15(b)(2))

[Author]

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