FAQs

To Receive Referrals From RE Agents:

No.
This solution is for individuals (such as individual brokers or individual loan officers) or entire companies; no integration is needed at all. The referrals are sent to your email and also displayed in your Go Fish Admin Panel.

To Receive Referrals From Brokers:

Yes.
This solution is for companies or sole proprietors that have the ability to integrate their LOS (Loan Origination System) or CRM (Customer Relations Management) system with our platform via our no-code Zapier interface (no coding or development required, performed by either our IT team free of charge or by your own IT team). The integration is required in order for our platform to track and recognize when the referring mortgage is approved and funded, so that the referring broker can be paid your chosen basis points at closing, no payment is conducted upfront, only if/when you close the mortgage.

To Receive Referrals From RE Agents:This solution is for individuals (such as individual brokers or individual loan officers) or entire companies.

To Receive Referrals From Brokers:This solution is for companies that have the ability to integrate their LOS (Loan Origination System) or CRM (Customer Relations Management) system with our platform via our no-code Zapier interface (no coding or development required, performed by either our IT team free of charge or by your own IT team).

Referral Receiver Defined:A company that is registered on this platform as a Referral Receiver which engages in either loan brokering or lending as well as all terms specifically directed to (“The Referral Receiver,” “Referral Receiver,” “Referral Receivers,” “Referral Receiver’s")

For Referrals From Brokers Only:Referral Receivers agree to choose a fee equal to a percentage of the loan amount and to allow GFO to auto-pay the Referral Sender upon the closing of the mortgage.

At that time, Referral Receiver agrees to allow GFO to automatically pay Referral Senders via ACH by charging the Referral Receiver first, then paying the Referral Sender.

Referral Receiver Is Restricted FromMaking Direct Payments To Referral Senders:

The Referral Receiver agrees to never try to offer or make an intention to offer a payment to a Referral Sender on the platform for services that the Referral Sender will, has, or can provide provided on The Platform.

Real Estate Agents

Go Fish Originators is fully RESPA-compliant because while it is called a referral in the general sense, there is actually no referral in the legal sense because you're not matching your referral to a Broker or Lender; you're simply submitting the lead to us (a lead distribution platform) that uses our smart algorithm to distribute it to the 2 highest-performing Brokers and/or Lenders in your state.

Permissible Marketing Activities

• Can provide lead contact info & their estimated overview of the lead to our platform

All marketing services must be genuine and value-driven, producing measurable exposure or engagement.

Prohibited Activities (RESPA Restrictions)

Under 12 CFR §1024.14(b), non-licensed agents may not:

• Receive compensation based on loan approval, funding, or closing
• Discuss loan terms, provide financing advice, or suggest specific loan products
• Collect financial or sensitive personal information from borrowers
• Accept or assist with applications
• Participate in any activity classified as a settlement service

Compensation Rules for Unlicensed Agents

• Flat Fee Per Lead: Compensation is strictly based on marketing outputs (e.g., leads, traffic) and not contingent on loan outcome.
• No Success-Based Bonuses: Any payment structure tied to a closed loan or approval is not permitted.
• Market-Rate Valuation: All fees must reflect the fair market value of services provided.

Who Is Regulated Under RESPA?

RESPA governs entities that provide settlement services in residential mortgage transactions, including:

• Mortgage lenders and brokers
• Real estate professionals
• Title and escrow companies
• Appraisers, inspectors, notaries, and others connected to loan closings

Lead Distribution Filters: Platform Feature & RESPA Analysis

Go Fish Originators allows lenders and brokers to apply non-personalized filters (e.g., borrower state, income range, property type) to opt out of certain leads.

Compliance Position:

• These filters are configured by the lender, not the platform or referring party.
• Leads are still distributed algorithmically to all referral receivers who meet the selected criteria.
• The platform does not recommend, match, or steer borrowers toward specific referral receivers based on financial information or approval likelihood.
• This design is consistent with "white-label lead generation" and is fully compliant under RESPA’s Section 8 and related HUD guidance, as long as no party is compensated for the mere act of steering.

Examples of RESPA-Compliant Payments

Non-Licensed Referral Agents:

• Flat fee per lead or impression
• Payments tied to website traffic, ad clicks, or content engagement

Licensed Mortgage Brokers

Permissible Activities

Licensed mortgage brokers and real estate brokers may engage in full loan origination services, including:

• Explaining loan options and the mortgage process to borrowers
• Discussing terms, rates, and product suitability
• Collecting borrower information and financial documentation
• Assisting with or processing loan applications
  (These services are explicitly permitted under RESPA – 12 CFR §1024.14(g)(1)(iii))

Compensation Structure

• Licensed brokers may be legally compensated based on a percentage of the mortgage amount upon closing, including success-based bonuses
• These payments are compliant when brokers perform bona fide origination services

Legal Details for Licensed Mortgage Brokers

To be compensated a percentage of the mortgage loan amount contingent upon loan closing and remain compliant with RESPA, TILA, the SAFE Act, and CFPB regulations, licensed brokers must perform bona fide loan origination services. These may include explaining the loan process, discussing loan terms, collecting borrower information, prequalifying financials, or similar activities. Simply referring a borrower to a lender without also performing origination services would violate RESPA, and receiving compensation contingent on the loan’s outcome without such services would violate TILA’s loan originator compensation rules. Therefore, bona fide origination services must be performed in addition to any borrower referral activity.

Conclusion

Go Fish Originators operates with a clear distinction between marketing and origination activities. Unlicensed agents are compensated strictly for measurable marketing work, while licensed brokers are compensated for mortgage origination. Our platform is built to uphold RESPA, TILA, and state-specific regulations, maintaining transparency, legal compliance, and consumer freedom at every step.

A: We confirm that only referrals sent through our system will be tagged as GFO referrals. This is handled via the URL structure that is tagged with the referral sender's ID. Referrals originating from us will land on your website with a URL such as: https://www.YourWesbite.com/?orig=1&tag=223.

In this example, the referral sender is identified as #223 from originator company #1 (representing GFO).

We will implement code on your website to capture these tags from the URL and insert them into your GFO Admin Panel so that you can see all referral agents and referrals there (and only those originated from GFO) in real-time. Our API pulls a READ ONLY (one-way) limited stream of data only associated with the originations we generated; it's like a mailman reading your house number but not being able to delivering mail through your front door slot. It's the most secure structure available, and many banks use this structure for their 3rd party integration.

Q: What happens if a borrower returns to re-refinance a loan that has already been funded and a referral fee has been paid? Will the referral partner receive payment again?

A: A referral sender will never be paid twice on the same loan ID.

Q: I read that applicants returning later (up to 6 months) are still tracked so the referral partner receives credit/payment. How is that tracked? If they return 6 or 12 months later, having forgotten who referred them, and simply go directly to my website, how is that linked back to the referral partner for credit?

A: We implement a tracking cookie on your website, typically placed in the <header> or <footer>, ensuring it functions across all pages. When a visitor first arrives via a referral link, the cookie is stored in their browser, capturing the referral source. This ensures that if the borrower leaves and returns later, even up to 6 months, the referral is still recognized. Even if they return directly to your website without using the original referral link, the cookie remains active and will credit the referral partner accordingly.