Loretta Salzano was recently featured in RESPA News warning lenders about the FDIC’s amped up attention to marketing service agreements (“MSAs”) and co-marketing with real estate professionals. Even those not supervised by the FDIC should be on guard in response to the CFPB’s recent RESPA FAQs, the change in CFPB leadership, and state regulators’ continued attention to MSAs, co-marketing and normal promotional activities like sponsorships and entertainment.
Examiners are digging in with detailed document production requests, and the narrative can be as important as the data. To thwart enforcement action, those engaging in such activities best be ready to prove to examiners that they are monitoring performance and otherwise minding the store.
As Loretta reminded RESPA News, despite the increased scrutiny, there are ways to legally engage in advertising and promotional activities with referral sources to increase business. Contact Loretta to learn how!