Loretta: I believe you are "kind of" correct- when RESPA was originally written they probably did not have VM"s, title brokers, per se, discount title wholesalers  or any of that to deal with when it came to defining the way this was set out, and I agree that it does become a little more complicated when you bring in sub-sub contractors- BUT- the way it reads is clear- fees paid are for title work- any split that occurs carries the corresponding liability along with it- so if company ABC is listed on the HUD- and you are paid out of ABC's fee, then their is a split with ABC- each has to carry liability insurance for their portion of that fee.The big part of that split is that for it to occur legally  there has to be "core title work" provided by each company- section 8 of RESPA is very clear about this- this does not mean ABC merely adds a different involve instead of yours to the title- if you follow what HUD is doing, they are catching up with this and fining heavily for these violations.I will be glad to send you the section 8 regs at the same time so you can read them- they are not exactly easy reading either- they are written to bore you after about 5 minutes think.
After reading them you might decide to get irate all over again thinking about all the money they have scammed off each of us.
I do find your posts interesting as this is the second time I have mentioned this particular RESPA violation and the last time I believe only one person noted it in a post- maybe we are becoming more aware now- hopefully, cause we all have something at stake, but only those that understand this will be able to make a difference in our business- there will always be those that are fighting for improvements in our profession and those that prefer to just discount the facts and go about their ways as always.I, for one, prefer to do my best to be positive and look forward to a more equitable future for all of us.
I am also a "proponent" of the on-line systems that we have here in Virginia-knowing that will bring a barrage of comments- and I welcome them- it has been the best thing that the Clerks and Courts have brought us as an advancement  for our industry. It has been evident from other posts that some elected officials in some states just don't have any morals to uphold and give away the whole farm as part of their re-election efforts. We do not have that problem here- there have been no breeches of the security systems and we have complete confidence in the States on line security requirements that are in place to secure the docs that are available.Discussions with the respective Clerks has been a great resource of information regarding their efforts to maintain the records securely- they have been very encouraging with this effort and the on-line systems.
I am more productive and accurate today than ever before- when I first started in this business,  four cases a day was tops- it was everything we could get done- today, I can process that many in a matter of a few hours, and still have time to take care of other things too.It has taken years of title plant accumulation and data base development, but it all has been worth it.
Now I will await the flood gates of encouragement to open up.
Steve Meinecke