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Marketing Pulse Aug 22

A RESPA ruling puts co-marketing agreements back under the microscope

A Missouri judge let Section 8 kickback and unearned-fee claims proceed against Veterans United on the same day Zillow''s amended RESPA complaint resurfaced — which makes this the week to audit how every marketing dollar you send an agent is documented.

Saturday, August 22, 2026 30Y 6.77%15Y 6.61%5/1 ARM 6.36%

The marketing story this week is a legal one, and it is closer to your daily work than it looks. A federal judge in the Western District of Missouri let the core RESPA claims against Veterans United survive dismissal: state consumer counts were tossed and most claims were time-barred, but Section 8(a) referral-kickback claims and Section 8(b) unearned-fee claims are both going forward. What the plaintiffs describe is a marketing arrangement — agents in a referral network routing roughly 35% of their commission, about 1.05% of the sale price, to affiliated entities, with the contested question being whether any real service was delivered in exchange. The same day, Zillow's third amended complaint in the Taylor suit landed, narrowed to five plaintiffs and stripped of its RICO counts but still pressing RESPA claims and citing a study estimating $2,881 in added cost per Zillow Home Loans loan. The through-line for a marketing plan is not "stop co-marketing." It is that the enforcement pressure is now coming from private plaintiffs reading your agreements, not only from an examiner, and the thing they read is whether the invoice describes work that actually happened at a price a stranger would pay. Separately, two consolidations closed their final gaps this week — Real Brokerage cleared Canadian court approval for the RE/MAX deal with an August 24 target close, and Two Harbors got final regulatory approval for the CrossCountry Mortgage transaction — which means a meaningful slice of the agent roster in your market is about to have a new brokerage on their business card. That is a real, non-manufactured reason to reach out.

On the rate side there is nothing dramatic to market against, and it is better to say so than to invent a move. Bankrate's 30-year is 6.72%, flat from yesterday, down two basis points on the week and up seven from a month ago — stable in the high-6s, not falling. The segment where the math genuinely works right now is narrower than the one everybody markets to: borrowers holding notes between 7% and 7.5%. On a $400K loan that band is worth roughly $75 to $211 a month at today's number, which is real money but not the kind that sells itself in a headline — it needs the borrower's own figure in front of them. Your government pipeline is the more urgent list. FHA moved from 6.32% to 6.38% and VA from 6.34% to 6.40% overnight while conventional held flat, so the gov-to-conventional advantage narrowed by about six basis points. Any FHA or VA comparison you sent earlier this week is now quoting a gap that no longer exists.

The tactical move is to run two lists this weekend and treat them differently. The first is compliance: pull every marketing-services agreement, co-marketing invoice, and lead-purchase arrangement you are party to, and for each one write a single sentence naming the service performed and how the price was set. If you cannot write that sentence from the file, that is the item to fix, and it is far cheaper to fix now than to explain later. The second is outreach: build the agent list for the brokerages changing hands and send a plain note that references the transition and offers nothing but availability. No co-marketing pitch attached — this week is exactly the wrong week for that, and a clean introduction ages better anyway.

Do this today

open your three largest co-marketing or MSA arrangements and, for each, write the one-sentence description of the service actually delivered and the basis for its price. Anything you cannot write goes on Monday's calendar with your compliance contact.

Borrower segments to act on today

FHA and VA files quoted before the gap narrowed

FHA moved 6.32% to 6.38% and VA 6.34% to 6.40% overnight while conventional held at 6.72%, cutting the gov-to-conventional advantage from roughly 40 and 38 bps to 34 and 32. Any side-by-side you sent this week overstates the gap.

active loans · fha/va
Notes in the 7.0 to 7.5 band — the quiet middle tier

At today's 6.72% this cohort saves roughly $75 to $211 a month on a $400K balance. Thin enough that a generic blast fails and a per-file number converts; break-even runs 24 to 30 months at standard costs, so lead with the borrower's own figure.

closed loans · ≥12mo since close · rate 7.00–7.50%

Today’s content angles

Text message

The one-number reply for anyone still deciding

Short text, no graphic: "Quick one — rates have held steady in the high 6s for about a month now, so the number on your file is the number. On a $400K loan today's payment runs right around $2,590 a month. If your current rate starts with a 7, tell me your balance and I'll send your two payments side by side today."

Tactics worth stealing

Every co-marketing dollar needs a service you can name

RESPA Section 8(c)(2) and Regulation X at 12 CFR 1024.14(g) protect payment for goods or facilities actually furnished or services actually performed at fair market value — nothing else. The practical test is whether you can write one sentence per invoice naming the service and how the price was set. If you cannot, a plaintiff reading the same file will reach the conclusion for you.

RESPA Section 8(c)(2); Regulation X, 12 CFR 1024.14(g)

A brokerage transition is a reason to write, not to pitch

Agents changing brokerages are re-evaluating every vendor relationship at once, which makes the note that offers availability and nothing else the one that gets answered. Save the co-marketing conversation for after the transition closes and the agent has their new compliance rules in hand.

Announced closings: Real Brokerage / RE/MAX (Aug. 24 target), Two Harbors / CrossCountry Mortgage