DENVER — “OK, people: Do not run your businesses based on videos made by mortgage brokers,” advised Brian Levy, an attorney at Kattan & Temple, at the RESPRO (Real Estate Settlement Services Providers Council) meeting today. Levy was referring to panicked phone calls he received earlier this year when his clients saw a video that two mortgage brokers put on YouTube.
- An investigation isn't guidance, but it can provide clues as to how the CFPB is interpreting co-marketing rules and regulations.
- Every participant in a co-marketing arrangement must pay a fair, proportionate price for his or her participation.
- Brokers should document what they're doing, value each piece of co-marketing material and train agents on compliance.