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).

1. Utilization of QR Codes:

Generate QR codes linked to the lender’s or broker's application and display them on business cards, flyers, or at physical properties during house showings. This provides a quick and easy way for potential buyers to access the loan application simply by scanning the code with their smartphones. You will get credit for the loan origination even if the borrower does not return to the lender's website for up to 6 months.

2. Email Signatures:

Include a link to a loan application in your email signatures to provide a persistent, accessible link to the application across all communications.

3. Local Networking Events:

Attend local business and networking events such as real estate investor meetups. This provides an opportunity to interact directly with potential homebuyers and investors.

4. Collaboration with Home Improvement Companies:

Partner with local home improvement companies or contractors and embed the lender’s or broker's loan application into their websites. This can facilitate financing for home renovation projects.

5. Educational Workshops and Seminars:

Organize or participate in educational seminars that guide potential buyers through the home buying process, including financing options. Share the lender’s or broker's application form during these sessions.

6. Integration with Property Management Platforms:

Collaborate with property management companies to include financing options in rental application and management platforms. This can help renters transition to homeownership.

7. Digital Marketing Campaigns:

Use digital marketing tools like email newsletters, targeted ads, and social media platforms to share the lender’s loan application links.

8. Partnerships with Local Businesses:

Form partnerships with local businesses to host information stands or kiosks that feature tablets or computers pre-loaded with the lender’s application forms.

9. Collaborative Real Estate Portals:

Collaborate with online real estate portals to embed the lender's application directly on property listing pages.

10. Local Government or Community Websites:

Partner with local government or community websites to embed loan applications, reaching residents looking at community development initiatives or affordable housing programs.

11. Real Estate Blog Integration:

Embed loan applications within real estate-focused articles or blog posts, providing readers with immediate access to loan applications.

12. Builders and Developers’ Websites:

Collaborate with builders and property developers to include the loan application on their project pages, especially for new developments or pre-construction sales.

13. Event Websites:

Create a dedicated event website or page where visitors can learn about real estate events and apply directly for loans. Embedding the application on the event page can capture the interest of attendees.

14. Local Chamber of Commerce Websites:

Embed loan applications on chamber of commerce websites to target professionals looking to invest in commercial or residential properties.

15. E-commerce Platforms for Home Products:

Partner with e-commerce sites that sell home-related products or services and embed loan applications to cater to customers who may need additional financing.

16. Social Media Platforms with Integrated Web Pages:

Use platforms like Facebook to embed a loan application form directly on business pages, making it easily accessible to followers.

17. Affinity Group and Alumni Association Websites:

Embed the loan application on these sites, marketing it as an exclusive benefit for members looking to purchase homes.

18. Interactive Online Tools and Calculators:

Integrate loan applications into tools such as mortgage calculators on websites frequented by potential homebuyers.

19. Real Estate Investment Forums and Blogs:

Partner with forums and blogs focused on real estate investment to embed loan applications.

20. Virtual Reality (VR) Home Tours:

Embed loan applications within virtual reality tours of properties to captivate potential buyers’ interest.

21. City or Neighborhood Guides:

Integrate loan applications into online guides that provide insights into living in different areas.

22. Employee Portals of Large Corporations:

Embed loan applications in employee portals as part of employee benefits.

23. Housing Fairs and Expos:

Embed loan applications on the event websites or on interactive kiosks at housing fairs and expos.

24. Wedding Planning Websites:

Embed loan applications on wedding planning websites to offer financing solutions for newlyweds planning their future.

25. Public Transport Websites:

Embed loan applications on public transportation websites, targeting commuters considering buying a home near their work or along transit lines.

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.

Legal Details For Licensed Mortgage Brokers

For licensed mortgage brokers to be paid a percentage of the mortgage loan amount contingent upon the loan closing and remain compliant with RESPA, TILA, the SAFE Act, and CFPB regulations, they must perform bona fide origination services. These may include explaining the loan process to the borrower, discussing loan terms, collecting borrower information, prequalifying financials, or other. Simply referring the borrower to a lender without performing any actual origination activity would violate RESPA, and receiving compensation contingent on loan closing without providing those services would violate TILA’s loan originator rules.

Legal Details for Real Estate Agents and Other Non-Licensed Individuals

1. No Origination Activity:

Unlicensed individuals who use our platform do not engage in any mortgage brokerage, origination, or settlement services, as defined under RESPA and the SAFE Act. They do not take applications, discuss loan terms, collect borrower financial information, or perform any duties that require licensure.

2. Marketing and Lead Generation Only:

These individuals provide bona fide marketing services, specifically through lead generation activities that direct prospective borrowers to our platform. They do not “refer” borrowers in the legal sense—meaning they do not steer, recommend, or match any borrower to a particular lender or broker. Their marketing efforts are general and public-facing.

3. Compensation Structure:

To ensure full compliance with RESPA, TILA, the SAFE Act, and CFPB regulations, unlicensed individuals are only compensated on a flat per-lead basis. This compensation is tied strictly to marketing output (e.g., ad clicks, traffic, form submissions) and not contingent on loan approval or funding in any way.

For more detailed information, please refer to our full FAQ and compliance overview.

Residential Mortgage Compliance Overview: Go Fish Originators Platform

The following outlines how all licensed and non-licensed referral agents on the Go Fish Originators platform conduct services in accordance with federal and state legal requirements related to Residential Mortgage Loans—specifically under the Real Estate Settlement Procedures Act (RESPA), Truth in Lending Act (TILA), Secure and Fair Enforcement for Mortgage Licensing (SAFE Act), and applicable state regulatory bodies such as California's Department of Financial Protection and Innovation (DFPI).

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.

Acceptable Marketing Activities That Include Displaying the QR Code or Referral Link Provided by Go Fish Originators

To comply with RESPA, TILA, the SAFE Act, and CFPB regulations, unlicensed individuals must engage in bona fide marketing services—not loan origination or referral-only activity.

These marketing services may include, but are not limited to, any of the following:

• Maintaining a public-facing website that promotes the lender’s services and prominently displays the referral URL link or QR code provided by Go Fish Originators, directing interested consumers to the lender’s official website or application portal
• Distributing promotional flyers, brochures, or printed materials containing lender branding and QR codes
• Creating and sharing lender-related content across social media platforms
• Running paid digital ad campaigns (e.g., on Facebook, Google, or display networks) that promote lender offerings
• Hosting online or in-person events, webinars, or informational workshops that feature lender content or branding
• Publishing blog posts or articles with embedded referral links or lender call-to-actions
• Sending email newsletters or SMS messages that promote lender services or direct users to lender resources
• Sharing lender QR codes or links in online communities, forums, or affiliate networks, with appropriate disclosures

All such activities must be general in nature and must not target specific borrowers or influence individual loan outcomes.

Also for all users on our platform to remain TILA compliant, Go Fish Originators ensures that compensation is provided strictly on a flat per-lead basis and is never contingent upon whether a borrower is approved for a loan or whether the loan is ultimately funded.

Non-Broker-Licensed Real Estate Agents

Permissible Marketing Activities

Non-licensed referral agents may only perform bona fide marketing services that have the potential to generate borrower interest or referrals. These activities must not involve any loan origination functions and may include:

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

• Operating a public-facing website that features lender branding, QR codes, or custom links
• Distributing flyers, brochures, or digital ads on behalf of a lender
• Running social media campaigns that promote mortgage services
• Creating educational or promotional content about a lender’s products or programs
• Hosting lender information on lead capture or advertising platforms

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.

Affiliated Business Arrangements (AfBAs)

AfBAs are allowed under 12 CFR §1024.15 when the following are in place:

• Written Disclosure to the consumer about the business relationship
• Clear notice that the consumer is not required to use a referred provider
• Payments reflect actual services rendered, not referral volume

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

Core RESPA Referral Requirements

To ensure compliance:

• Disclose all financial relationships in writing
• Maintain consumer choice—borrowers must be free to select service providers
• Ensure that fees reflect real services—no compensation for mere referrals
• Marketing services must have standalone value, unrelated to loan outcome

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 evenly and automatically to all lenders who meet the selected criteria.

• The platform does not recommend, match, or steer borrowers toward specific lenders 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 Brokers:

• Commission tied to loan closings
• Percentage-based compensation structures

Fee Integrity & Documentation

All compensation must be:

• Documented and agreed upon in writing
• Reasonable for the services performed
• Not inflated to disguise referral payments

Automated Payments & Platform Controls

Go Fish Originators ensures full compliance through:

• Free platform access for both licensed and unlicensed users
• Automated flat-fee payments based on pre-agreed marketing deliverables
• No success-based incentives for unlicensed parties

TILA Compliance Considerations

Although Go Fish Originators does not fund loans:

• Licensed brokers must present accurate APRs, terms, and disclosures as required by TILA
• Unlicensed agents must ensure all promotional content is factual and not misleading

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.

Overview for Commercial Real Estate (CRE) Loans Only

Go Fish Originators provides a compliant platform for individuals to conduct loan referrals exclusively for commercial real estate (CRE) loans. The legality of this structure is rooted in the fact that non-licensed originators on our platform do not engage in any brokered loan origination activities—they do not discuss loan terms, provide lending advice, accept loan applications, or collect borrower information (such as income or tax documents).

Instead, unlicensed referral agents operate as intermediary marketing promoters. Their role is to promote participating lenders in a general and compliant manner, such as by sharing the lender’s website or QR code, directing interested parties to the lender’s official website or commercial loan application.

This approach ensures that all referral activities are conducted in full compliance with applicable commercial lending laws and regulations. Non-licensed referral agents avoid all activities that would require a mortgage broker or loan originator license. They strictly provide promotional services designed to increase visibility and awareness of the lender—not to handle any borrower-specific details or negotiations.

Role of Licensed Commercial Mortgage Brokers

Licensed commercial mortgage brokers on the Go Fish Originators platform are authorized to engage in loan origination activities. This includes:

• Discussing commercial loan terms and products with borrowers

• Offering lending advice and structuring options

• Accepting and processing commercial loan applications

• Collecting borrower information required to evaluate or submit a deal

LLicnsed brokers are responsible for ensuring that all commercial loan-related activities are compliant with applicable federal and state laws. Their role is more hands-on in the financing process and includes providing borrowers with accurate and professional guidance throughout the transaction.

Marketing Compliance for Commercial Loans

Even though consumer protection laws like TILA do not apply to commercial real estate transactions, truthful and non-deceptive marketing practices are still essential to maintain transparency and regulatory compliance. The following standards apply:

Non-Licensed Agents – Marketing-Only Role:

• No loan discussions: Non-licensed agents must not discuss loan terms, rates, or lender underwriting guidelines with borrowers.

• General promotion only: Agents may share lender branding, website links, QR codes, or host public-facing web pages with lender promotions, but they must not tailor content to specific borrower circumstances.

• Truthful content: All promotional materials must fairly and accurately represent the lender’s commercial offerings. No misleading claims or rate promises are permitted.

Licensed Brokers – Direct Involvement:

• Authorized to discuss loan terms: Licensed brokers may communicate loan amounts, structures, terms, and lender requirements directly with commercial borrowers.

• Detailed marketing allowed: Licensed brokers may advertise specific commercial loan offerings, including rates, LTV ranges, and terms, provided all claims are truthful and reflect actual lender offerings.

• Responsibility for compliance: Licensed brokers must ensure that all marketing and communications related to CRE financing comply with applicable commercial lending regulations and state-level financial laws.

Compliance Summary

Go Fish Originators separates non-licensed promotional referral activity from licensed commercial loan origination to ensure platform-wide legal compliance. Non-licensed agents act solely as marketers and cannot participate in any settlement service activity or offer borrower-specific guidance. Licensed commercial brokers, on the other hand, are authorized to guide clients through the loan process and be compensated based on the outcome of funded transactions.

All agents—licensed or not—must represent lender services accurately and transparently, and must avoid compensation structures that could be construed as referral fees without services rendered. This model upholds the integrity of commercial lending standards while creating a compliant channel for lead generation and loan origination collaboration.

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.