There are very specific regulations regarding "gifting" your clients in these industries. It is our understanding that if you were to use an incentive as a way to "bribe" a customer or anyone for that matter into sending you referrals would be against regulation. However, if you use it as a gift after the purchase, just as a thank you to your customer, it is our understanding that this scenario would be in compliance. This was found directly on the RESPA website: Can a lender give a borrower an incentive, such as a chance to win a trip or a rebate, for doing business with the lender? RESPA does not prohibit a lender or other settlement provider from giving the borrower an incentive for doing business with it as long as the incentive is not based on the borrower referring business to the lender. Also, you can use incentives as lead generators to help boost response rates to your ads. I.E. "Call us for a free quote and receive a $25 restaurant certificate, No Purchase Necessary." You are not requiring anyone to pay you any money so this strategy would be in compliance. We have heard that Insurance companies cannot spend more than $12 on a gift for a customer. Since you pay $99 a month to give away as many as you need; how much did the certificate end up costing you if you factor the $99 divided by how many you gave away that month? Even most of our Premium Certificates can be purchased for less than $12 each. Also, since your customer has to participate by sending in fees to receive the incentive gift, you are not actually giving them a vacation that you paid for. You are simply presenting them with the opportunity to take advantage of a really great offer if they are willing to participate. Since you are not purchasing the vacations outright, using our marketing incentives in these industries is compliant.