Legal
Effective date: April 1, 2026 · Last updated: August 21, 2026
About this policy
This policy describes how Meridian's co-marketing feature is designed to comply with the Real Estate Settlement Procedures Act (RESPA), specifically Section 8, which prohibits kickbacks and unearned fees in connection with real estate settlement services. This policy is provided for informational purposes and does not constitute legal advice.
RESPA Section 8 prohibits any person from giving or accepting a fee, kickback, or thing of value pursuant to any agreement in connection with a real estate settlement service referral. However, RESPA permits payments for goods actually furnished or services actually performed, including co-marketing arrangements where payment is proportional to the value of advertising space or services provided. The CFPB has issued guidance indicating that lender-agent co-marketing arrangements may be permissible when: (1) payment is based on the fair market value of the advertising space, not on referrals; (2) the advertising space is actually provided; and (3) there is no agreement to refer business.
Meridian's co-marketing feature is designed with these platform rules: Proportional billing: The lender is charged a percentage of the agent's actual plan price (Founder or Agent), not a hardcoded $99. Combined lender share across all live partnerships cannot exceed 50% of that plan. The agent subscription is discounted by the same cents so Meridian collects the plan price once. Co-branding while billed: Lender name, company, NMLS number, and an "Advertisement / Co-marketing" label appear on listing, portal, CMA, and flyer chrome only when the partnership is active and the lender has paid (leftover-days stub or a full cycle). If a payment fails, co-branding is removed. First month: Lender billing is aligned to the agent's Stripe cycle. If the agent is already paying, the lender is charged a prorated leftover-days amount immediately and the agent receives that same amount as a Stripe customer-balance credit on their next invoice. If the agent is still on a trial, the lender is not charged and ads stay off until the agent's first paid invoice. After that, both sides bill the split monthly. Ad space: Stored adSpacePct always equals sharePct. Branded chrome (listing header and footer, portal header and contacts, CMA header, flyer footer) is split by that percent. Pay 50%, occupy 50% of that chrome. Listing photos and body copy stay listing content. No referral conditioning: The platform has no mechanism to condition advertising space on referrals. Audit trail: Partnership and payment events are written to an append-only event table (plus a JSON copy for older rows). Agents and lenders can export a CSV. Platform operators with database access can still mutate data; treat the log as an operational record, not a cryptographic ledger. NMLS: An NMLS number (4–12 digits) is required to create a partnership and is shown to consumers when co-branding is live.
Meridian does not: facilitate any agreement to refer settlement service business; allow lender payments that exceed the fair market value of advertising space; allow advertising space that is disproportionate to lender payment; allow co-branding to be hidden while billing is active; condition lender payments on actual referrals made.
While Meridian's platform is designed to facilitate RESPA-compliant co-marketing, users remain solely responsible for: ensuring their overall business practices comply with RESPA; not entering into any side agreements with lenders that condition advertising on referrals; consulting qualified legal counsel before entering into co-marketing arrangements; maintaining their own records of co-marketing activities; ensuring their lender partners understand the terms of the arrangement. Meridian is a technology platform and does not provide legal advice. The fact that Meridian generates an audit trail does not constitute a representation that any particular arrangement is RESPA-compliant.
Each arrangement records: creation time; agent and lender identifiers including NMLS; share % and matching ad-space %; the locked FMV layout recipe (surfaces, split, monthly dollars); billing activation, invoice paid, payment failed, and deactivation events. New events are appended to co_marketing_audit_events. A CSV export is available in the lender portal. The log is not a write-once legal archive.
Meridian enforces a 50% cap on combined lender share of the agent's actual subscription plan in the partnership-create transaction and again before billing activation. Share is computed from the live plan (Founder $19 or Agent $99), not a fixed $99.
If you have questions about RESPA compliance or Meridian's co-marketing feature, please contact us at legal@osmeridian.com. We recommend all users consult with a real estate attorney familiar with RESPA before entering into co-marketing arrangements.