RESPA Section 8 generally prohibits giving or accepting a fee, kickback, or other thing of value in exchange for referrals of settlement-service business connected to a federally related mortgage loan. That's why we don't build referral incentives into our relationships with loan officers or mortgage brokers.
State insurance law is a second, separate layer. Many states independently restrict paying commissions or referral fees to unlicensed individuals for producing insurance business, which can reach Realtors, loan officers, and mortgage brokers whether or not RESPA applies. Paying no referral fees at all avoids the question rather than relying on a narrow exception.
Put simply: rather than building a compensated relationship and structuring it carefully, we built a relationship with no compensation in it.