FAQs
For RE Agents
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Why Real Estate Agents Use Our Platform
Help Your Home Buyer Get an Additional Quote: Buyers always want to compare rates or get a second opinion — agents refer them to us for an extra quote from top-performing brokers or lenders, and still get paid $100 for the referral.
Get All Your Leads Pre-Approved First: Before investing time showing homes, agents use our platform to get every buyer pre-approved through top-performing brokers and lenders.
Get Them Funded: Once pre-approved, buyers are guided through the funding process by lenders who go the extra mile to help get deals closed.
Ghosted by Buyers: When buyers stop responding, agents send us the lead and still earn $100 — no follow-up or chasing needed.
Overflow Leads: Busy agents with more leads than they can handle send the extras to us and get paid without losing focus on their core pipeline.
Buyer Has Financing Issues: When a buyer has credit problems or isn’t yet ready to qualify, agents refer them to us — we route them to lenders who specialize in tough cases, and the agent still gets paid.
Monetize Non-Closing Leads: If a deal falls apart or a buyer walks away, the agent can still earn by passing the lead to us for another shot at funding.
Lead Isn’t a Good Fit: When a lead is outside the agent’s area, price range, or target clientele, they send it to us instead of letting it go to waste — and earn $100 every time.
Out-of-Budget Clients: Buyers who want more than they can afford are routed through our system to lenders who can reset expectations and offer realistic options — while agents get paid.
Non-Closing Leads: Even if the buyer doesn’t purchase, the agent still gets rewarded just for submitting the lead — turning dead ends into new opportunities.
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I normally deal with a select group of brokers & lenders…
You can see & message which broker or lender the referral was sent to and build a relationship with them. And a new feature coming soon allows you to see the broker or lender the referral is being routed to “before” you submit it.
For Mortgage Brokers
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Is Integration Required?
Do I need to integrate Go Fish with my LOS, CRM, or any other system?
Short answer: No — brokers can start using Go Fish immediately with no integrations required.
Here’s how it works:
- Instant delivery. Every homebuyer lead is delivered to your Go Fish admin panel and also emailed directly to your inbox.
- Simple to manage. View, track, and manage all leads and referral activity inside your Go Fish account — no technical setup needed.
- Optional exporting. If you prefer, you can export leads into your CRM, download them as a CSV file, or generate a PDF report. These are conveniences — they are not required to use the platform.
If you can check email, you can use Go Fish. We keep it intentionally simple so brokers can focus on closing loans, not configuring software.
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Is This For Individual People (Brokers, Loan Officers, ect.) or Companies?
To Receive Referrals From RE Agents:This solution is for individuals (such as individual brokers or individual loan officers) or entire companies.
Legal Compliance Explained
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RESPA’s Section 8(c)(2) Safe Harbor Provisions + SAFE Act, TILA Act + CFPB & HUD Guidance
Legal Oversight & Counsel
Go Fish Originators (“GFO”) has been developed under the guidance of Geraci Law LLP, nationally recognized specialists in private lending law. Their expertise in mortgage regulatory compliance, including RESPA, TILA, and CFPB oversight, forms the foundation of the platform’s structure. With Geraci’s counsel, GFO has been intentionally designed to meet — and in many areas exceed — federal and state compliance requirements.
Legal Definition of Referral Under RESPA
Under the Real Estate Settlement Procedures Act (“RESPA”), a “referral” is defined as “any oral or written action or communication directed to a home buyer which has the effect of affirmatively influencing the selection by said home buyer of a provider of a settlement service or business incident to or part of a settlement service.” See 24 CFR § 3500.14(g) (Regulation X implementing RESPA).Why A GFO Lead Does Not Constitute a Referral
Go Fish Originators (“GFO”) and its participating real estate agents do not engage in referrals as defined under RESPA. Crucially, the consumer (home buyer) never sees, is presented with, or is influenced by any “preferred pool” or ranking of mortgage brokers. Real estate agents do not discuss or disclose broker options with the consumer at all, nor do they endorse or recommend any broker.
Instead, real estate agents perform independent lead generation activities and submit consumer inquiry data to GFO as part of a bona fide marketing arrangement. GFO, in turn, distributes those leads to contracted mortgage brokers through a neutral algorithm that includes the brokers based solely on their pre-set preferences and objective eligibility filters. At no point do real estate agents control the broker selection process. This structure ensures that no referral, steering, or unlawful exchange of value occurs, as defined under RESPA Section 8(a).
Conditions Supporting Non-Referral Characterization
To ensure that lead distribution through GFO does not constitute a “referral” under RESPA, the following structural and operational safeguards are in place:
- No Consumer-Facing Broker Communication by Agents:Participating real estate agents do not communicate with consumers regarding any mortgage broker options. They provide no recommendations, suggestions, comparisons, or disclosures—whether express or implied—that could influence the consumer’s broker selection. This ensures the absence of both active and passive steering.
- No Agent Control Over Final Broker Assignment: While agents may designate a “Preferred Pool” of mortgage brokers within the internal platform interface, such designation is advisory only and does not control or determine which broker ultimately receives the lead. Agents do not directly assign or route leads to any specific broker.
- Platform-Controlled, Neutral Algorithmic Distribution: Lead distribution is conducted exclusively through GFO’s automated algorithm, which relies on objective, pre-set criteria such as broker geographic coverage, product compatibility, and availability. Agents have no ability to override, adjust, or influence lead routing after submission. Broker selection occurs independently of agent input at the point of lead transfer.
- No Broker Lists Presented to Consumers: At no time is the consumer presented with a list of mortgage brokers to choose from. The consumer is not shown any curated broker options, rankings, or profiles that could create the appearance of a recommendation or induce a selection. This structure eliminates any consumer-facing influence that could give rise to a referral characterization.
- Non-Contingent Agent Compensation: Agent compensation is flat, formulaic, and based solely on marketing services actually performed. Payment is not conditioned on which broker receives the lead, whether the loan closes, or any consumer outcome. This compensation structure ensures compliance with RESPA Section 8(c)(2), which allows bona fide payments for services rendered and precludes any unlawful benefit tied to referral activity.
Together, these safeguards demonstrate that GFO’s platform is structured to avoid the hallmarks of a referral under RESPA, as defined by 24 C.F.R. § 3500.14(g), and instead functions as a compliant, non-directional marketing lead service.
Kickback Prohibition
RESPA Section 8(a) prohibits the payment or receipt of any fee, kickback, or thing of value in exchange for referrals of settlement service business.How GFO Is Legally Compliant With This Provision
Section 8(c)(2) provides a safe harbor for payments made in exchange for bona fide marketing services actually performed.
Here is the exact legal wording:
(c) Exceptions / Allowed Payments
"Nothing in this section shall be construed as prohibiting ...(2) 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."
GFO’s compensation structure fully complies with this exception: the marketing service provided by participating real estate agents is lead generation, a recognized and legitimate form of marketing. Also, importantly, no funds ever flow directly or indirectly from mortgage brokers to real estate agents. This independent and non-transactional payment structure eliminates any risk of being classified as a kickback or unlawful referral fee under RESPA.
Legal Compliance Statement
Go Fish Originators (“GFO”) is specifically structured to comply with all applicable federal and state laws, including but not limited to the Real Estate Settlement Procedures Act (“RESPA”), the Truth in Lending Act (“TILA”), the SAFE Act, and Consumer Financial Protection Bureau (“CFPB”) guidance. Compliance is integral to the platform’s operational framework and algorithmic design. These laws and guidelines are not addressed in isolation, but instead have been holistically incorporated into every element of the platform's design—from lead routing logic to compensation methodology—ensuring that all core compliance elements reinforce and support each other.
1. Nature of Services
GFO operates solely as a lead generation platform. At no point does GFO receive or provide anything of value contingent upon, or conditioned on, the selection of any particular mortgage broker. All broker engagements generated are classified as marketing leads, and all payments are tied strictly to marketing services—not loan closings or referrals. GFO does not engage in mortgage origination or provide settlement services.2. Non-Steering Design
Real estate agents using the platform may create and rank a “Preferred Pool” of mortgage brokers. Importantly, no broker is guaranteed a lead. Distribution is governed by GFO’s automated algorithm. If one broker declines or does not respond within the designated timeframe, the lead is automatically and neutrally cascaded to the next broker in the pool, consistent with that broker’s stated preferences and filters. This structure ensures:- Allocation is determined solely by the platform’s neutral algorithm, not by agent influence.
- The Home Buyer is never shown the Preferred Pool or provided with broker options to choose from.
- Real estate agents do not recommend, discuss, or present any mortgage broker options to the Home Buyer, ensuring no affirmative influence or referral occurs.
3. Compensation Structure
Real estate agents are compensated solely through flat marketing stipends administered by GFO. Compensation may vary based on neutral, standardized lead characteristics (e.g., estimated loan size, property type, or geographic location) to reflect fair market value for GFO's marketing-only services. All stipends are formula-driven, applied uniformly across all brokers, and are never contingent on loan outcome, broker selection, or agent discretion. As a result, the platform design prevents and does not allow steering. This compensation structure is fully consistent with RESPA, TILA, and related regulatory guidance. GFO’s model adheres to RESPA Section 8(c)(2), which permits payment for bona fide marketing services actually performed.- Flat stipend administered solely by GFO, independent of broker selection.
- Any variation is strictly based on neutral, standardized lead characteristics (e.g., estimated loan size, property type, or geographic location) to reflect fair market value.
- Stipends are formula-driven, applied uniformly across all brokers, and not contingent on loan outcome, broker ranking, or agent discretion.
- The platform design does not allow and fully prevents steering.
- All payments constitute permissible marketing fees and are consistent with RESPA Section 8(c) safe harbor provisions, TILA, and related regulatory guidance.
4. TILA Compliance
Agent compensation is never tied to loan percentage, loan approval, or closing success. Stipends are flat-fee based and are paid as a marketing expense of GFO, not as transaction-based compensation. GFO’s structure prevents any incentive that could create steering risk or borrower harm, aligning with both the letter and spirit of TILA compensation rules.5. SAFE Act Compliance
GFO does not engage in mortgage loan origination or any activity requiring a mortgage loan originator license. The platform strictly provides marketing leads and administrative support to licensed mortgage professionals. At no time does GFO accept or process loan applications, negotiate or discuss loan terms, or provide guidance on credit products. All engagement with borrowers is limited to lead distribution under standardized, neutral algorithms. Because all mortgage-related activities remain the exclusive responsibility of licensed mortgage professionals, the platform is fully compliant with SAFE Act licensing and regulatory requirements.6. Broker Payment Flow
Mortgage brokers compensate GFO for lead access. Separately, GFO compensates participating real estate agents with a flat stipend. At no time do funds flow from a broker to an agent, directly or indirectly. This clear separation of payments reinforces compliance with RESPA Section 8(a), which prohibits kickbacks or referral fees between settlement service providers. GFO’s role is strictly limited to intermediary marketing functions.7. Scope of Authority
GFO does not:- Accept or process mortgage applications.
- Negotiate, advise on, or set loan terms.
- Collect borrower financial documentation.
GFO’s Compliance Safeguards
Preferred Pool Mechanism- Agents refer into a ranked pool, not to any particular broker.
- Algorithmic distribution prevents directed steering.
- Agent compensation is identical regardless of broker selection.
Equal Compensation- Flat, fixed stipend per engagement.
- No variability tied to broker choice, loan size, or loan outcome.
No Loan-Based Incentives- Agent stipends are not percentage-based, volume-based, or contingent on closings.
Independent Payment Flow- Brokers pay GFO for lead access.
- GFO, as a marketing platform, compensates agents separately.
Broker's Lead Distribution Filters & RESPA AnalysisThe platform permits brokers to configure non-personalized filters (e.g., geography, income range, property type).- Filters are determined by the broker, not by the agent or GFO.
- Lead distribution remains algorithmic and neutral, and is very much based on more than 10 broker filter settings.
- GFO does not recommend, influence, or match borrowers to specific brokers.
ConclusionGFO’s business model has been, at great financial cost & opportunity cost, proudly & intentionally engineered for regulatory compliance.Its processes and compensation structures are consistent with:- RESPA Section 8(c)(2) safe harbor provisions
- TILA disclosure and compensation restrictions
- SAFE Act licensing requirements
- CFPB & HUD enforcement guidance
On a personal note, beyond strict legal adherence, GFO has also designed its platform and business model to comply with “the spirit” of residential mortgage regulations as well, which are intended to ensure that home buyers are provided with fair, transparent, and unbiased access to mortgage options, and are not steered away from the best possible options for their needs.Through this framework, GFO ensures consumer choice, transparency, and compliance with all governing laws, while maintaining a neutral, algorithm-driven lead generation system. The platform is intentionally designed to provide home buyers with access to the most qualified, vetted, and elite mortgage broker options in the country.