Maybe this is a stupid question, but if there is no ABA, why the heck does it matter at all? If I want to place a mortgage brokerage, a realtor, and an appraiser in my office, sitting at desks in each corner of the room, and charge them a sugar coated donut a day for rent (maybe a cup of coffee, too), there would be no problem so long as they are not referring business to me. Section 8 of RESPA is supposed to prevent kickbacks... not generosity. If you are getting nothing in return, I don't even think RESPA is a factor.
Just my opinion... I don't get it.
Best,
Robert A. Franco
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