I remember a similar situation several years ago in which one of my clients was on trial, and the issue arose as to whether my law firm was an independent or captive law firm of the client. This was not a Respa case, but I was called to testify in the matter, and there were a number of badges of independence to prove independence. A simple majority of the badges established the independence. Some of the questions I was asked by the prosecutor were...Did I have a separate entrance to my firm...Did I have a separate sign in front of my office...Did I pay rent...Did I have other clients...and the laundry list went on.