How LoanPath IQ Approaches RESPA

1. What Is RESPA?

The Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. § 2607, is a federal consumer protection law administered by the Consumer Financial Protection Bureau (CFPB). RESPA Section 8 prohibits any person from giving or accepting a "fee, kickback, or thing of value" in exchange for the referral of settlement service business involving a federally related mortgage loan.

LoanPath IQ supports the goals of RESPA and has structured its business model to align with both the letter and spirit of the law.

2. Our Business Model

LoanPath IQ is a mortgage marketing and borrower-intake technology platform. LoanPath IQ does not originate loans, broker loans, issue pre-approvals, quote interest rates, provide loan advice, underwrite loans, make credit decisions, or perform loan settlement services.

LoanPath IQ operates in two distinct capacities:

As a marketing platform: We operate a network of approved marketing partners — publishers, content creators, licensed real estate professionals, and other marketers — who promote a borrower pre-qualification intake tool to their audiences. This is a controlled mortgage marketing arrangement using approved campaigns, approved tracking links, documented consumer consent, fixed front-end compensation, and compliance review.

As a technology intermediary: We provide the technology infrastructure that captures borrower intake information, verifies consent, and routes structured borrower data to licensed mortgage professionals who have contracted with us to receive verified inquiries.

LoanPath IQ separates residential borrower-intake workflows from commercial financing inquiry workflows so that each flow can use appropriate forms, routing rules, consent language, and disclosures.

3. Commercial Financing Inquiries

LoanPath IQ may also support commercial or business-purpose financing inquiries through a separate commercial intake flow. Commercial financing inquiries are handled separately from consumer residential mortgage pre-qualification requests.

Commercial financing may include business-purpose real estate loans, investor loans, rental-property financing, commercial property financing, bridge financing, DSCR-style inquiries, or other business-purpose financing requests. Commercial and business-purpose financing inquiries may be subject to different federal, state, licensing, advertising, privacy, and lender-specific requirements than consumer residential mortgage loans and are handled separately.

LoanPath IQ does not make commercial loans, broker commercial loans, underwrite commercial loans, approve commercial loans, issue loan commitments, provide credit advice, provide investment advice, or guarantee financing. Any financing decision, loan terms, eligibility determination, rate, approval, denial, or funding decision is made only by participating lenders, brokers, capital providers, or financing professionals.

To reduce compliance risk, LoanPath IQ separates commercial inquiries from residential consumer mortgage inquiries using separate forms, separate routing rules, separate disclosures, separate consent language, and separate lead classification. If a submission appears to involve an owner-occupied consumer residential mortgage request, LoanPath IQ may route the inquiry through the residential borrower-intake flow or place the inquiry into compliance review.

• Commercial inquiries must be tagged separately from residential consumer mortgage inquiries.
• Commercial forms must ask whether the financing is for business, investment, rental, or owner-occupied consumer residential purposes.
• Owner-occupied consumer residential mortgage requests should not be processed as commercial leads.
• Commercial marketing partner compensation, if any, must still be based only on approved marketing activity or verified front-end intake submissions.
• Commercial marketing partner compensation must not be based on funded loans, loan amount, lender revenue, interest rate, points, origination revenue, or the value of any financing transaction.
• Commercial lenders or financing providers are responsible for determining their own licensing, disclosure, underwriting, and compliance obligations.

4. Partner Compensation and RESPA Section 8

What we pay partners for

LoanPath IQ's approved marketing partners are compensated for a single, specific, documented event: a verified, consented, non-duplicate borrower-intake submission. This is a front-end marketing event — the borrower has filled out a pre-qualification intake form with documented consent through the partner's approved marketing channel.

Compensation is not tied to any lender-side process event — credit pull, 1003 completion, disclosure issuance, underwriting decision, closing, or funding. Partners are paid the same fixed flat fee for a verified intake submission regardless of what the lender does afterward and regardless of whether the borrower ever obtains a loan.

Partner compensation is set in advance and is intended to be reasonably related to the fair market value of the approved marketing, advertising, traffic, and borrower-intake services actually performed, without considering the value of any potential mortgage transaction or referral.

LoanPath IQ maintains fair-market-value support for partner compensation rates, including marketing activity, media value, traffic quality, verification costs, and intake services actually performed. Compensation is not calculated from loan revenue, loan value, or expected settlement-service revenue.

Why this is not a RESPA referral fee

RESPA Section 8(a) prohibits fees paid "pursuant to any agreement or understanding" for the "referral" of settlement service business. A "referral" under RESPA is any oral or written action that has the effect of directing a person to a particular settlement service provider. LoanPath IQ's partner compensation structure does not constitute a referral fee for the following reasons:

1. 1

   Partners are compensated for a marketing activity, not a referral act.

   Partners are paid for generating a verified borrower-intake submission through their approved marketing channels. The compensation is for the marketing work performed — creating content, running campaigns, sharing a pre-qualification tool with their audience — not for directing a specific borrower to a specific lender.

2. 2

   The compensable event is a front-end intake submission — not a lender process milestone.

   Compensation triggers when a consented, non-duplicate intake form is submitted through the partner's marketing channel. It does not depend on the lender pulling credit, issuing disclosures, approving the loan, or closing the loan. This structurally separates the partner fee from the downstream lender transaction.

3. 3

   Compensation is a fixed flat fee, not based on loan size, loan amount, interest rate, or lender revenue.

   Partner compensation is fixed in advance and does not vary based on loan size, loan amount, interest rate, loan type, lender compensation, approval, closing, funding, or whether the borrower ultimately obtains a loan.

4. 4

   Partners do not direct borrowers to a specific lender.

   LoanPath IQ's marketing partners promote the LoanPath IQ pre-qualification intake tool — not any specific lender. The routing of a borrower to a specific licensed mortgage professional is performed by LoanPath IQ's platform based on objective criteria. The partner has no role in, and receives no compensation based on, which lender the borrower is ultimately connected with.

5. 5

   The arrangement is disclosed through LoanPath IQ's partner agreements, public compliance disclosures, borrower consent language, and applicable platform documentation.

   LoanPath IQ's partner agreements, this public disclosure page, and the borrower consent language on our intake forms describe the existence and nature of the marketing partner arrangement consistently and transparently.

5. The Bona Fide Services Safe Harbor

RESPA Section 8(c)(2) provides that nothing in Section 8 prohibits "the payment to any person of a bona fide salary or compensation or other payment for goods or facilities actually furnished or for services actually performed."

LoanPath IQ's structure is intended to align compensation with bona fide marketing and intake services actually performed. Approved marketing partners create content, operate advertising campaigns, maintain websites, build audiences, and generate verified borrower inquiries. The compensation paid is for those marketing services — not for the act of referral — and is intended to be reasonably related to the value of the services performed.

6. Licensed Real Estate Professionals

LoanPath IQ's Realtor Partner program is subject to additional consideration under RESPA because licensed real estate agents are themselves settlement service providers in residential transactions. We address this directly.

Realtor partners are compensated for the same front-end marketing activity as all other partners — a verified, consented, non-duplicate borrower-intake submission. Realtor compensation is not contingent on the borrower's loan closing, on a specific lender being chosen, or on any lender-side process event. Realtors do not direct borrowers to a specific lender; routing is performed by the LoanPath IQ platform.

This program is not intended to operate as an Affiliated Business Arrangement (AfBA) under RESPA and Regulation X because LoanPath IQ has no ownership or control relationship with any mortgage lender, and Realtor partners do not refer consumers to a commonly owned or controlled settlement-service provider.

All Realtor partners must acknowledge in their partner agreement that: (a) they have reviewed participation in this program with their broker or are independently authorized to participate; (b) they understand that compensation is for marketing activity, not for referring clients to a specific mortgage lender; and (c) they are responsible for ensuring their participation complies with their brokerage's policies and applicable state real estate licensing laws.

Realtor partners may not receive compensation for one-to-one recommendations made to active buyer or seller clients in connection with a pending residential real estate transaction. Realtor participation is limited to approved general marketing activity, approved public campaigns, and approved content distribution. Realtor partners must obtain broker approval where required and must not steer consumers to a specific lender, broker, loan officer, or settlement-service provider.

7. Borrower Consent Practices

Every borrower who submits a pre-qualification inquiry through LoanPath IQ provides explicit, documented consent before their information is shared with any mortgage professional. For each submission we capture:

• The exact consent text version presented to the borrower, including the identity of the licensed mortgage professional(s) who may contact them.
• The timestamp of consent, the borrower's IP address, and the device/browser used at the time of submission.
• Consent records are retained in accordance with LoanPath IQ's record-retention, legal, compliance, and privacy policies.
• Routing limited to the parties identified in the consent text — borrower information is not shared with parties not named in the consent.

LoanPath IQ uses clear, documented, seller-specific consent practices designed to support compliance with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and to reduce call and text risk for our lender partners.

8. Operational Safeguards

• Partner fees are fixed in advance.
• Partner fees are not changed based on close rate, loan amount, loan approval, disclosure issuance, underwriting status, funding, closing, or lender revenue.
• Partners do not select the lender or loan officer that receives a borrower inquiry.
• Partners may not recommend, steer, or direct a consumer to a specific lender, broker, loan officer, or settlement-service provider in exchange for compensation.
• Borrower routing is based on objective criteria such as licensing coverage, state availability, product fit, operational capacity, and borrower-submitted information.
• Closed-loan data may be used for internal quality review and campaign optimization only, not partner compensation.
• Partners must use approved campaigns, approved copy, approved landing pages, and approved tracking links.
• LoanPath IQ may reject, hold, or reverse leads for fraud, duplication, missing consent, invalid information, or non-compliant marketing activity.
• Residential consumer mortgage inquiries and commercial/business-purpose financing inquiries are classified separately in the platform.
• If a borrower indicates the property will be owner-occupied or used for a consumer residential mortgage purpose, the inquiry should be routed through the residential borrower-intake flow or compliance review.
• Commercial inquiry data is not used to create residential mortgage partner payout events unless the submission separately satisfies the approved residential borrower-intake requirements.
• Partner compensation rates are not increased, decreased, tiered, rebated, or retroactively adjusted based on loan approval, disclosure issuance, underwriting outcome, closing rate, funded volume, lender revenue, or the value of any mortgage or financing transaction.
• Any ambiguous inquiry should be placed into compliance review before routing.

9. Our Commitment

LoanPath IQ is committed to maintaining audit-ready records and responding appropriately to lawful regulatory inquiries. We have designed this platform with the following principles:

• Transparency first.

  This disclosure page, our partner agreements, our borrower consent language, and our lender contracts all describe the same business model in consistent terms.

• No hidden arrangements.

  There are no side agreements, undisclosed compensation arrangements, or fee-splitting arrangements that are not described in our public disclosures.

• Audit-ready records.

  Every lead, every consent record, every status change, and every partner payout event is logged with a timestamp and user ID. Our records are available for regulatory examination upon lawful request.

• Pre-launch legal review.

  LoanPath IQ intends to have its compliance framework reviewed by qualified RESPA and TCPA counsel before any lender or Realtor partner goes live, and to update our practices as regulatory guidance evolves.

10. Regulatory and Compliance Inquiries

Regulatory agencies, legal counsel, or other parties with questions about LoanPath IQ's compliance practices may contact us at:

We respond to regulatory inquiries promptly and cooperatively.