Compliance · Real-estate referrals

State-by-state real-estate referral framework

Migration Concierge LLC partners with licensed real-estate brokerages in each operating state to maintain the licensed-broker chain on both sides of every referred transaction. Full operational doc: compliance/state_real_estate.md.

Universal principle

Every state requires that a person receiving a real-estate referral fee hold an active real-estate license in some jurisdiction. RESPA (12 USC 2607) applies to federally-related mortgage transactions and prohibits unearned fees or kickbacks unless the recipient is performing a service for the fee. Migration Concierge partners with licensed brokerages to maintain the licensed-broker chain.

Operational gates per partnership

  • Written referral agreement.
  • Receiving brokerage license verification.
  • Originating (Migration Concierge partner) brokerage license verification.
  • Documented fee structure within the standard 25%–35% market range.
  • Consumer-facing RESPA + state-specific disclosure language.

State-by-state notes

  • California (FL/CA origin households). CA Bureau of Real Estate requires the referring person to hold an active CA real-estate license. Migration Concierge partners with a CA-licensed broker; referral fee must be paid broker-to-broker.
  • Florida. FL Real Estate Commission (FREC) requires active FL real-estate license to receive a referral fee. Same broker-to-broker chain.
  • Tennessee, Texas, Idaho, North Carolina, Arizona (destinations). Each state permits broker-to-broker referrals under written agreement. Migration Concierge partner brokerage in the destination state pays the originating broker the referral fee at close.
  • Standard fee structure. 25%–35% of the receiving brokerage's commission at close. Disclosed up front to the consumer per FTC + each state's REC requirements.

What we do not do

  • We do not list properties.
  • We do not show properties.
  • We do not negotiate purchase or sale contracts.
  • We do not collect commissions directly from buyers or sellers.

RESPA Section 8

Mortgage referrals are subject to RESPA Section 8 prohibitions on unearned fees. We do not receive compensation from mortgage lenders for referrals on federally-related mortgage transactions unless a documented service of value is performed for that fee under an Affiliated Business Arrangement (ABA) disclosure. We default to no compensation on mortgage referrals until we have a counsel-approved ABA in place per partner.

← Back to disclosure