In September 2014, the CFPB ordered Michigan title insurance agency, Lighthouse Title, “pay $200,000 for illegal quid pro quo referral agreements.”

• In September 2014, the CFPB ordered “Lighthouse Title, a Michigan title insurance agency, to pay $200,000 for illegal quid pro quo referral agreements.” [Press Release, “CFPB Takes Action Against Mortgage Kickback Agreements”, Consumer Financial Protection Bureau, 09/30/14]

• The Bureau determined that Lighthouse Title had “violated the Real Estate Settlement Procedures Act [RESPA].” RESPA prohibits, in addition to other actions, “providing something of value to any person with an agreement or understanding that the person will refer real estate settlement services.” [Press Release, “CFPB Takes Action Against Mortgage Kickback Agreements”, Consumer Financial Protection Bureau, 09/30/14]

• Lighthouse Title, which provided other “mortgage-related services” to consumers in addition to title insurance, “entered into marketing services agreements [MSAs] with various companies, including, for example, real estate brokers, with the understanding that the companies would refer mortgage closings and title insurance business to Lighthouse.” These quid pro quo arrangements “made it appear as if the payments would be based on marketing services the companies were supposed to provide to Lighthouse. However, Lighthouse actually set the fees it would pay under the MSAs, in part, by considering the number of referrals it received or expected to receive from each company. The CFPB’s investigation found that the companies on average referred significantly more business to Lighthouse when they had MSAs than when they did not.” [Press Release, “CFPB Takes Action Against Mortgage Kickback Agreements”, Consumer Financial Protection Bureau, 09/30/14]

• In addition to the monetary penalty imposed by the CFPB, Lighthouse was “required to terminate immediately any existing MSAs with companies in a position to refer business to Lighthouse, and is prohibited from entering into new MSAs with any such companies.” [Press Release, “CFPB Takes Action Against Mortgage Kickback Agreements”, Consumer Financial Protection Bureau, 09/30/14]