Back in October, 2015, the CFPB issued a Compliance Bulletin to remind participants in the mortgage industry of the prohibition on kickbacks and referral fees under the Real Estate Settlement Procedures Act (RESPA) and to describe the substantial risks posed by entering into Marketing Services Agreements (MSAs). The link to the Bulletin can be found here.

In light of these regulatory developments, we recommend having any of these MSAs that you have in place reviewed.

If you have any further questions or would like to discuss having your MSA(s) reviewed, please email Amanda Smith (asmith@cusolaw.com) or Jennifer Winston (jwinston@cusolaw.com).