Legal Question in Real Estate Law in Florida

Possible RESPA violation?
Before I ask my question, here is my situation.

I own a fee-based Financial Education company that teaches people how to best reduce their mortgage and other debts. In some cases, our clients need to get a Home Equity Line of Credit. Although, I have a mortgage broker's license in the State of Florida, I do not, under any circumstances, do the Home Equity Line of Credit. Instead, we only give our clients a form to help them ask the right questions so that they don't get screwed when they speak to the bank of their choosing. We don't collect any referral fees from the banks. We charge a one-time flat fee for our service that is fully refundable should they not be satisfied.

SO, my question is:

Is it a RESPA violation to have a referral incentive program to our current clients? Am I violating RESPA is if tell them that if a person they refer to my company signs up with us, they will receive something ($150, or a gas card, etc.)?

Thanks in advance.

Asked on 8/31/08, 5:33 pm

Alexander M. Rosenfeld Rosenfeld & Stein, P.A.

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0 attorneys agreed

Re: Possible RESPA violation?

Not really knowing what you do, the full range of services provided, it is not possible to provide a reliable reply.

Answered on 9/01/08, 10:56 am

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