Can a lender work with realtors to market each other’s clients without any compensation exchanging hands?

It’s a tricky question, and the reason I think it’s tricky, is the question, “is there a thing of value going back and forth for a referral?” And a thing of value could be non-monetary; it doesn’t have to be cash or cash equivalent. So, there can’t be a thing of value being paid, or being provided in return for a referral. In the example provided, I don’t know what they are doing for each other, and if that is in return for referrals. It may simply be a matter of two people marketing each other and not having an agreement about referrals. Theoretically that’s okay, but again, you’re going to have a tough time proving that you don’t have an agreement regarding referrals.

Answered By: Brian Levy