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It is said that if all the hunters on opening day(s) of deer season in Wisconsin were grouped together, they would comprise the sixth largest army in the world! Sometimes lenders feel that they have a target on their backs, and here at the WMBA’s 49th Annual Real Estate & Finance Conference in Milwaukee, some of the informal talk in the hallways is about avoiding redlining, a focus of audits and exams. Another is RESPA. When does “As you wish” or “intent” figure into lending? “Rob, is it true that the same business lunch can either be a RESPA violation, or not?” I am not an expert in compliance, but yes, that is true. If you’re an LO who takes a real estate agent to a nice lunch as a thank you for sending business your way, that is seen as a thing of value and would be a RESPA violation. If the same nice lunch is used to discuss new programs and training that your company offers real estate agents, then it is copacetic
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