Referral Fees

News & Analysis as of

CFPB's First Consent Order of 2014 Addresses RESPA Section 8(a) Kickback Scheme

The Consumer Financial Protection Bureau (CFPB) issued its first enforcement order of 2014 against a St. Louis mortgage lender, Fidelity Mortgage Corporation (FMC), and its president, Mark Figert. The January 16 consent order...more

Advisory Opinion 14-01: OIG Says No AKS Sanctions for Senior Communities that Compensate Referral Source

In its first Advisory Opinion of 2014, the Department of Health and Human Services Office of Inspector General (“OIG”) found that an arrangement between a placement agency (the “Placement Agency”) and certain senior...more

Is It Illegal to Have Distributors Earn Income by Referring Others?

We are often asked by executives starting a network marketing company if they can have consultants earn income by referring others and if it’s legal. Effectively, multilevel marketing is the sale of products through...more

Sixth Circuit Rejects HUD Test For RESPA Affiliated Business Safe Harbor

On November 27, the U.S. Court of Appeals for the Sixth Circuit held that HUD’s supplemental ten factor test for determining whether RESPA’s affiliated business arrangements safe harbor applies is not entitled to deference or...more

False Claims Act Litigation Update: Florida Federal Court Finds Hospital Violated Stark Law Via Oncologist Bonus Compensation...

On November 13, 2013, the United States District Court for the Middle District of Florida granted partial summary judgment in favor of the United States inUnited States ex rel. Baklid-Kunz v. Halifax Hospital Med. Ctr., et...more

Florida District Court Orders Disgorgement Of Profits From Unfair, Deceptive Online Payday Loan Referral Practices

On July 18, the U.S. District Court for the Middle District of Florida held that an online payday loan referral business engaged in unfair and deceptive billing practices and failed to provide adequate disclosures to its...more

Patton Boggs Reinsurance Newsletter - June 2013: California Federal Court Grants Motion to Compel Production of Reinsurance...

Munoz v. PHH Corp., No. 1:08-cv-0759-AWI-BAM, 2013 WL 684388 (E.D. Cal. Feb. 22, 2013) and Munoz v. PHH Corp., No. 1:08-cv-0759-AWI-BAM, 2013 WL 1278509 (E.D. Cal. Mar. 26, 2013). In two separate rulings, a California...more

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