DC RESPA Crackdown & Joint Venture Rules with Marx Sterbcow | Title Agents Podcast Ep26

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Hello everyone, and welcome to the title agents podcast, where we bring you expert insights, actionable strategies, and the latest trends shaping the title industry. I am your host, Mo Shamil, CEO of Alltech National Title. Today, we're diving deep into RESPA compliance, your favorite, regulatory updates, and best practices with one of the foremost experts in the field, the man, the legend, Mark Sterbko. Get ready for a conversation that's packed with knowledge to help you stay ahead of the curve. Let's dive in.

Welcome, Mark. How are you? Doing terrific, Mo. Thank you for having me. I appreciate it.

Yeah. Thank you so much for taking the time to do this. That means a lot and I appreciate you shedding some lights on the latest that's going on in RESPA compliance and all the action, all the, what do you call them, the fines that's going on within the industry. It's been a quiet couple of years, it seems, right? Let's dig right in.

Mark, can you tell us a little bit about your journey? How did you get started in law and what led you to specialize in RESPA in the title industry? Those are excellent questions. I'm going to go off the cuff here. So, I grew up, I guess it's a longer story.

I grew up in New Orleans. My father was in the real estate brokerage business and he ran one of the largest real estate brokerages in the country. They had a mortgage operation, a property and casualty division. He was the first person to advertise on the internet, the real estate industry, back in 1988 on a system called Genesis. This was before CompuServe, before Prodigy, before AOL, a long time ago.

So, it was actually like a third brother to me, just the internet and my brother and I, because my dad was constantly using technology and he was really far ahead, even today, some of the stuff that he implemented. But I did that, went into law school, just knew I wanted to go into law. Where'd you go to law school? I always ask this question. I went to law school at Gonzaga.

I didn't even know I applied. I don't know how I got in, but I remember getting the acceptance letter and I go, man, I got in Gonzaga and then I'm getting a scholarship too. It's your charm, Marks. Yeah. I'm like, where is this place?

I've never heard of this place. They notified me that I needed to acclimate myself to the Northwest because it's Spokane, Washington. So, they said, listen, you're not going to start in the fall with the rest of the students because you're not used to the Northwest. So, you're going to be part of our diversity crew and we're going to bring you in with all of the other diverse candidates from across the globe. And so, we started in the summer program to get used to Spokane and it was such a unique experience.

I had people from Thailand. I had people from all over and then there were three of us from the South. We had three white Southern guys from the South, one from Huntsville, Alabama, another one from out in South Carolina. So, it was the three oddballs with just really this mesh of people. So, it was a learning experience for you.

It really was. It was awesome. So, I did that, graduated from there, then got my LLM in real estate law. It was John Marshall School of Law. There were two LLMs in real estate.

It's now the University of Illinois at Chicago. What does LLM stand for? Just for those that may not know. I don't know. I don't know what it stands for.

It's like a master's degree of law. Yeah, okay. So, I threw that in. But I did that and during this process, my dad had asked me to come back to New Orleans to help him with a technology piece. I had set up my own law firm right after law school.

We landed some two massive billion dollar projects in Miami right out of the gate, which was unusual. He asked me to also come and help set up this technology stack that he was building. Part of the technology stack is he wanted to make the brokerage, the front end and back end of the brokerage completely paperless and have it integrated in with our mortgage operation, our property and casualty agency. He said, I need a title company built too. So, I'm like, so you're throwing me into the mix here to start a title company sight unseen from scratch and then help build a technology platform.

I'm like, okay, this sounds like a fun project. I did that for a number of years. In 2003, we actually got, we integrated everything together, mortgage title, PNC, the brokerage and allowed consumers into the transaction platform. So, we were 100% paperless back then, which was really highly, no one else had done it. That's awesome.

And it was fun just learning the different experiences. With that, there were a lot of RESPA pieces that were in play that you had to cost allocations here. And we're dealing with technology, which really no one had really thought of back in 1974 when RESPA was developed. So, it was on the cutting edge of trying to do cost allocations and making sure everything was priced right. And at that time, I reached out to some folks at HUD, Ivy Jackson, Bart Shapiro for guidance because they were in charge of the RESPA division.

And I'm like, look, can I allocate it this way? Can I allocate it that way? And got to be good friends with them. And if I had a question, I could email them at 11 o'clock at Saturday night and I'd get a response by 1 a.m. It was just a really unique experience dealing with the regulators.

So, we put that in place primarily for a couple of reasons. One, we had seen what Hurricane Andrew had done back in 1992 and how it destroyed Homestead, Florida. And there was a large real estate brokerage down there called the... And so, we had done a lot of research to make sure that if a hurricane had hit our operation, which is based in New Orleans, we don't want to go down. We want to have duplicate sites, mirrored sites all over, and we don't want to go down.

And at the same time, we want our consumers, as consumers have lost everything under the sun back in Homestead, we wanted a portal that consumers could come in who bought a house through us that they could see all of their mortgage data, their insurance data, their title stuff, and their real estate brokerage documents. We didn't foresee Hurricane Katrina and Hurricane Rita a week after that coming in and disrupting it. And when we did that, our system never went down. We were the only company that had everything up. I think actually, I will say, I think we were down for approximately one hour right after Hurricane Rita hit because we had our mirrored site in Lake Charles, Louisiana, and we were in the process of moving it to L3 up in Kansas.

But for that one hour, we were down. But other than that, we never went down, none of our operations. And we were on the forefront of really helping get the city back up and running at that time. It was a very unique time, but it was really cool. The agents used our platform system.

I think we had about an 80% adoption rate of our platform where the agents used it more than three times. The consumers came in, they loved it. Unique part was when Katrina hit, just like Holmes said, people lost everything. And during that process, we went in and told the consumers where they could find their insurance documentation, who their insurance agent was. So it was things like that really made that transaction post-closing a lifesaver for a lot of people because a lot of people didn't know who their mortgage company was, who their insurance company was.

They didn't know where to turn. And luckily we had that repository. So we did that. And then I did that until about 2008. During that time, I learned a lot about RESPA.

And then I got to be good friends with Grant Mitchell, who actually wrote the RESPA regulations for HUD or wrote a significant portion of those. And then got to know Phil Shulman really well, love Phil to death, and Jay Varon, and Richard Briono. You got to meet the whole kind of, it was a small, very small crew, Paul Schieber. I'm sure I'm missing one or two others, Loretta Salzano, Brian Levy. So I got to meet some of those folks.

At the same time, I got to go to the Realty Alliance meetings and just different things. So I got to see all the different angles of the real estate brokerage business, the property casualty insurance side, the mortgage side, and the brokerage. So it was a really unique experience where you're learning how everything interacts and intersects, which most people don't. They weren't lucky enough to have that sort of experience. I was extremely privileged in that case.

I've learned quite a bit. And then it feels like you need to get into RESPA. You'd be great at RESPA. So I'm like, Phil, I don't know anything about RESPA. He says, just listen to me and you can just wing it.

That's what I did. And here I am today. Did he tell you a joke while at it? That's right. There were several jokes.

That's great. The SerbCo Law Group has earned reputation as a leader in this space. Could you share the story behind founding the firm and your vision for its role in the industry? We smell twists in your arms. great at Respo.

So I'm like, Phil, I don't know anything about Respo. He says, just listen to me and you'll, you can just wing it. That's what I did. And here I am today. Did he tell you a joke while at it?

That's right. There were several jokes. That's great. The, this, this, the Sterbco law group has earned reputation as a leader in this space. And could you share the story behind founding the firm and your vision for its role in the industry?

We feel twists in your arms. Yeah, he was definitely a mentor. A lot of these folks were mentors in the business. And I think from Sterbco law, I had before Sterbco law, I had another law firm of the Sterbco Weiss and Ortiz. And we had an office in Miami and Chicago with Seattle and New Orleans.

It was just a, it was a lot of moving parts for all that. And I made a strategic decision. I don't want all that. I just want to concentrate on myself and be able to do some things without, I don't want to be in the real estate brokerage space. I really wanted to blaze my own path.

And so I did a lot of the work at Ladder & Bloom at the time for effectively for free from, I think until last year, I think I finally got some minimal salary, but it was all basically paid work. And it was a lot of work, but I enjoyed the rest of the part of the technology aspect of it. It was fit into what I liked in law and as well as the industry and started my own firm. And I based out here out in New Orleans, but I think. So you're like on the road most of the year.

Yeah, that was pretty much it. And I think because of the experiences that I had, other brokerages, other lenders started hiring me and it just ballooned and went cuckoo for Cocoa Puffs after that. It really has gotten to the point where it can be a little overwhelming at times. Like I started there and it's really been shocking to see how fast it's grown. But well, we're very blessed to have you.

This field, this niche of the niches, it is definitely a landscape where regulators can make up their mind as they go. It's like a minefield. It is. I think it's been one of the good pieces is establishing that relationship with HUD early on, with the regulators early on was really, was very helpful. And in having drinks with them and things, you got to hear things that you normally wouldn't hear.

And you can share some things about the industry that they don't know. So it makes it a little bit of a collaborative piece there. But once they get to know you, once they trust you and they realize you're not out there to take advantage of people. Which was one of the things after I left Lateran Bloom or left the operation, I did a bunch of RESPA class action lawsuits against the industry. But I did see some abuses out there.

So I think that also helped too with the regulators is that it wasn't so pro-defense that I also saw the other side of consumers and where there were abuses. And unfortunately, that's the regulators. They mean well, and they literally think that everybody's out there to get the consumer. And I would say 95% of the players in the industry get there. I would agree with that.

I would say probably 98% are fantastic. If you have 2% that are problematic and out of the 2%, it's the 1% that are real troublemakers. And those are the ones you really need the regulators to come in and clean these people out and get them out of the industry. Because it paints a bad brush over everybody. And that is something that I don't like to see.

I'm very protective of all the industries, but I don't like where you have some companies, especially during 2008, where you had the AmeriQuest of the world and some of these others that really took advantage of people. Fortunately, it's a lot more difficult to do what they did back in that time period. But there's still a few bad apples here and there. As they say, greed never goes away. Yes.

And especially when you have declining market, it creates a lot more pressure on companies to do all sorts of crazy things. You do need the enforcement attorneys or the enforcement, whether it be the state attorney generals or the CFPB or OCC. They have to come in and eat one of the industries every once in a while to keep everybody on their toes. What are the most significant changes in RESPA regulations over the past year? And how are they impacting tele-agents and affiliated business arrangements specifically?

The most significant change is about to be the one that's going to come through the MLS, through that litigation. That's going to be the NAR litigation. Actually, the settlement is today. I think the judge is signing off on it today. Today is November 26th.

Today is the day that the judge basically ignores everybody and just rubber stamps this settlement and moves forward. Is that a positive thing? It depends on which side. It's certainly going to be disruptive. And we're moving into a completely new home buying, home sale process.

Unfortunately, you have NAR and some of the large brokerages that aren't really telling everyone what is going on in the industry. And that's strategic because they don't want to spook their members and have members leaving in mass. Some of these brokerages don't want their agents to know as well because they may collect a desk fee or something. They want that revenue coming in. And unfortunately, in my opinion, I think it's a self-serving and greedy way to go about the industry because you have people's livelihoods and their families that are on the line.

And they really do deserve to know what this impact is going to be. And it's not going to be all this rosy impact that people are talking about right now, whether it's the same old thing, nothing's going to change. It's going to be some fairly significant changes that create some pressure on a lot of brokerages. And a lot of those brokerages are going to be forced to have affiliated businesses, much more so than ever before. And I think you're going to see the same with agents and agent teams as well.

There's just going to be a massive and dramatic increase. And I've already started seeing it. But I think when these changes hit and my conservative timeline is, let's say, 24 months, I think it's between 24 to 36 months from now. It could be quicker, but I think that's when we're going to see some real movement in the industry for some of the larger brokerages to shed themselves of liability and to adopt this new model. I've been preaching and also our team is preaching to all the people, like you exactly said, people think if you dig your head in the sand, things will be just fine.

They're so oblivious, they don't want purpose, they don't want to know what's coming. They're definitely going to put a pressure on the commissions, I think the estimate 20-30% at least, like a compression of the commission, especially the buyer side. And it's honestly shown in the earnings, public companies, like last quarter, it's already going to compress. I think where you're going to see it, there's a tale of two brokerages. You have brokerages that are heavy on the buy side, representing purchasers.

You have brokerages that are heavy on the listing side. Let me give you the financials of it. So this is some Steve Murray's numbers from a couple of years ago. The average real estate brokerage per transaction or their profit per transaction pre-tax, depending on the region of the country in which you're located, is between $250 to $50. So that's effectively a 6% commission, maybe a hair below that.

But when you start compressing that commission, now all of a sudden, companies start going out of business because they are living on very small margins. They've given the ship to the agents, and so the agents are making these real big, heavy splits. They're making all the money. The brokerage is basically the flawed model, as I've been saying for years. And I think one of the things that you're going to see come out of this is they're going to have to change the commission splits.

There's no question about that. But it's also going to force a heck of a lot more affiliated business arrangements for these companies to survive. And to put it in perspective, in 2008, at the height of the downturn, out of the top 100 real estate brokerages in the United States, 98 of them lost money. So we were one of the ones that did not lose money in 2008, and that's because we adopted all that technology and shed a lot of costs out. But outside us, we were really an anomaly there.

There are other brokerages, very large brokerages, including one in your neck of the woods, Daton, that was an independent. I remember he was telling me he was losing around $3 million a month, but he was making up for it on the ancillaries to be able to make payroll and pay for office leases and printers and copiers and the other stuff. And there was another one, a very large one up in the Midwest. He told me he was losing about $8 million a month out of his operations. Those are big dollars.

There's a lot of overhead and training and things that people don't really account for, where these costs for brokerages, you need to operate a brokerage. So this consolidation is going to certainly impact these folks. What I see is, I think there's an infight right now between the buy side brokerages and the listing brokerages. The fight right now is that we pull out of the cooperative compensation rule completely and we don't share commissions. We don't offer commissions to the buy side.

Now, the other side. So this consolidation is going to certainly impact these folks. What I see is, I think there's an infight right now between the buy side brokerages and the listing brokerages, the fight right now is do we pull out of the cooperative compensation rule completely and we don't share commissions, we don't offer commissions to the buy side. The other side is, we want to keep the clear cooperation policy in place at any and all cost because if we lose that, our broker, we might as well shut the doors down. So I anticipate, and there's been some media coverage on it a little bit, where Compass and Berkshire versus Keller Williams and Remax or EXP in particular, where they're fighting each other, Compass and Berkshire or anywhere, they have a lot more, they're heavy on the listing side.

I think with these changes, the model is going to be he who controls the online real estate is going to control the model. So in that online real estate is the listings. I'm sure you're familiar, Co-Star won all in and spent billions of dollars to control that listing. I think the big loser is going to be Zillow because their whole model is digital buyers. Co-Star's bad names haven't been mentioned.

Co-Star. $2.6 billion is what they invested into analytics reports and AI. And so when you have a Co-Star who will, in all likelihood, control the entire real estate market sphere from a data perspective, when they also own Apartments.com and they also own LoopNet, you're talking about commercial and apartment data. Now you mix the residential end. There is not a better repository, any pool of real estate data than what Homes.com is accumulating.

And their model is smart. You're listing your lead. So it really cuts out the referral brokerage model for buy side because what is a buy side commission worth now? A lot of these sellers, you're already starting to see it, especially in higher priced homes where they're not offering any money to the buyer's real estate agent. And I'm hearing that more and more, especially the $3 million and up category.

That's going to start trickling down over time. It's not going to be all overnight, but it's going to trickle down. What I do see in addition to Homes.com, and I'll talk about that one in a second, is the part where you have buy side agents. You're seeing a lot of buy side agents now migrating to become listing agents because the smart ones see what's taking place in the industry. And at the same time, you have listing agents that are creating listing agent teams or large listing agent teams.

When that consumer lead comes in through Homes.com, that listing agent, they may be a dual agent or they just assign it to a junior level or another agent and their brokerage to handle the buy side transaction. And they will at the end of the year, every six months, they'll work out their own financials as part of its team. That I think is going to be the model. It's going to significantly curtail the number of purchase agents across the United States. And with the new administration, hopefully that will put a halt to this a little bit or slow it down.

I don't think so. And I'll tell you why. So the NAR settlement, which is being classified as a national settlement, it really isn't a national settlement. It's a settlement among a few states with a few brokerages. And it's a settlement in terms that it doesn't impact non-NAR MLSs other than the couple of them that opted in.

It doesn't impact real estate brokerages that were over $2 billion that did not opt in to the NAR settlement. They didn't want any part of it, that goofy suit. Why would you go subject yourself under that goofy formula that NAR came up with the plaintiff's attorneys? It makes no sense. So you basically go at it alone.

What has been created now is a hodgepodge of laws in different states and there's confusion. The one thing that no one likes is confusion in the marketplace when you have this level of dysfunction in the real estate brokerage industry and confusion. When brokerages can't explain what the new changes are, when agents can't understand what the new changes are, and they're all expected to explain it to consumers, it creates even more confusion and bewilderment. And some of the state purchase contracts that I've seen are buyer representation agreements. Some of these documents are so convoluted and confusing.

Even somebody with a PhD in nuclear physics couldn't figure these things out. There was one the other day I looked at, I won't say the state, but I sat there with two other attorneys and we represent some companies in connection with the MLS stuff. We couldn't figure this thing out. It made no sense. Having said that, I think that Trump administration will probably give about a two year period of time for the industry to sort things out.

If they can't sort it out, then a DOJ is going to come and it's going to sort it out for them. And how are they going to sort it out? Basically what I just said, they're going to create a model where the sellers cannot compensate the purchasers of property. It's just going to be a hard one. That's where I think it's ultimately going to head.

Do I like that model? Not really. But considering some of the goofiness that you're seeing with people who are not the brightest in the business, there is a lot of shenanigans there. You have to protect consumers and you got to protect the industry too. That's really probably the best way to do it across the board, unfortunately.

So let's shift back to the title industry again, and now we have the respite to deal with. Now we have state general attorneys to deal with as well as another layer, and specifically like the recent enforcement in DC that affected a couple of my friends in the industry that I know they're totally out guys and do things the right way and work with you, which is the best of the industry. Can you shed some light on what happened in DC and what other AGs and different states are? DC was a bit of an anomaly. I did represent a company that was the last to settle just a few weeks ago, maybe about a month ago.

But DC, I was not part of the original four, the Allied, the KVS, the Modern or Union. I know exactly what took place with those. So I would say that the attorney general, when they were first looking at this, they were looking at it from a respirator. And so with my client, I'm like, these guys have done everything above and beyond. There's nothing that they have to worry about.

Like they are probably the cleanest I've seen anywhere. And I think in my client's case, they had about a little over 30 agent investors. Some of them weren't even agents. Some of them were just business lawyers for different firms and stuff that had invested in. I think it was $235,000 of initial capitalization for a 25% ownership interest, which that's for 25%.

They put a lot of money into this thing. It had staff, it had employees, it had a significant amount of outside business. They did their own work. The consumers had the option. Their pricing was average in the marketplace to below average.

So I think in my client's case, their pricing was actually, when you include both, their pricing was below average. With all this said, the state attorney general and DC, I don't think it was really about affiliated businesses. In fact, I'm confident that the enforcement actions weren't about affiliated businesses. What the enforcement actions were about is the high cost of title insurance in the District of Columbia. If you saw Brian Schwab's press releases, he kept talking about that.

It was all about the high cost of title insurance. Schwab is the attorney general in DC, correct? That's correct. There's a rating bureau in DC, so all of the title insurance underwriters, their insurance policies are all the same price for the most part. There is no difference if you went to Fidelity versus First American versus WFG versus TRG.

Everybody's the same. So from that perspective, you're not going to see fees being inflated or not. If you do see it, it's going to be maybe on the company that's doing the escrow and settle. I think most of the companies, I think three of the five were title issuing only. I think the other two of the five were full title agency.

The title agency ones, certainly their fees were average. They weren't higher than everyone else. I know we had done a spreadsheet. I think we had close to 90 companies in the market, the largest companies in the market. We did cost comparisons and stuff.

Consumers are actually saving money using these folks. There's no required use. It's very optional. In fact, with mine, the capture rates were significantly low. I think the capture rates were maybe around 13%, 16%.

That's not really evidence of steering by any means whatsoever. So having said all, giving you that background, throughout the process, you had the alternative. and stuff, and like, this is, consumers are actually saving money using these folks. Doesn't, there's no required use and it's very optional. In fact, with mine, the capture rates were significantly low.

I think the capture rates were maybe around 13%, 16%. That's not really evidence of steering by any means whatsoever. So, having said all, giving you that background, throughout the process, you had the alternative title insurance piece being pushed through on a national level. I'm not going to, I'd be shocked and stunned if DC and the CFPB were not coordinating hand-in-hand together. I would say the likelihood of them not would be like lightning striking me right here, right now with no clouds in the sky.

So, there was a lot of alternative pieces there. The reason that the title insurance premiums are so high in the district is because of the claims, and they are high. It has the highest transfer tax in the United States. And that transfer tax, the folks that work at the office, the government office there that hand out the numbers, they often get them wrong. And so, the title insurers are constantly having to pay out claims based on a lazy bureaucrat who just throws out a number and say, yeah, that's a number.

You're not going to fix that. It's an issue that the industry can't solve. It's an issue that the government has to solve to get competent people in place. So, that's really the true reason why the title insurance rates are so high there in DC. As the AG's office was going through this process, we provided them with a gazillion studies and research reports, which they didn't know anything about and really educated them on the process.

But they were bound and determined to come down the title industry for that national release to try and put pressure on the title insurance industry to lower their rates. So, by doing so, they went after the affiliated business industry, which low-hanging fruit for a lot of folks out there, especially for folks that don't like it. And when you have people that advocate to get rid of all affiliated operations and you provide that to the regulators, that's great. But those regulators have their own little political piece to this as well. They don't really care about the little guy in DC that may not be competitive in the marketplace.

They care about a bigger political issue. And they really don't care about the consumers that much. They're looking for some talking points that they can get votes for. So, as we went through this process, it was clear and apparent that it was all about title insurance, about the premiums being too high. So, interestingly enough, the DC City Council a few years back was going to adopt RESPA and they adopted a RESPA-like provision.

And they were going to adopt the safe harbor provision of RESPA in the code. And for some reason, they either forgot to add it or it just got lost in the paper shuffle, but they didn't codify that little part. So, DC, the Attorney General said, hey, we don't recognize the safe harbor. We don't have a safe harbor for RESPA, but for affiliated businesses. So, they're all illegal.

Interestingly enough, the Department of Insurance and Business or Insurance Securities and Business, DISB, on their website, they actually said that real estate agents can own interest in a title agency so long as they follow the RESPA policies and procedures. I mean, clear as day. They took it all a couple of months ago, but they didn't have any restrictions on it, nor did when they submitted their data to the National Association of Insurance Commissioners when they were looking at affiliated business study. They said, yeah, we don't have any restrictions on affiliated businesses. So, you have DISB going out and saying one thing and then the Attorney General saying, oh, don't listen to them.

Other unique part of this case is that the DISB is actually authorized to – they have to actually send a referral to the Attorney General's office to start an enforcement action. It didn't happen in this case. There was no referral. The D.C. Attorney General just decided to take this up on his own.

Unusual, but there was some lobbying on the back end by some folks who I know. You and I know exactly. I will say that my former CFPB friend did a very good job of using his network of influence to get some of the things accomplished that he wanted, and D.C. was one of them. So, they used the Consumer Protection Act there, and with that, the way that they've applied the Consumer Protection Act is actually scary.

So, it's one thing to go after companies that are doing things wrong and hitting them for respite violations. It's another to advocate to get rid of all affiliated businesses, not knowing what the impact of that's going to be, because these people in the regulator's office, they don't have any clue what title insurance is, what affiliated businesses are. They're just going to go adopt something with half the information and run with it, and that's what we had here. So, D.C. now, because of these enforcement actions and the way that the Attorney General has enforced it, it means that any affiliation with a title insurance agency or underwriter is effectively illegal in the District of Columbia.

That means if I'm a lawyer and I have my own separate title agency, that's illegal in the district. If I'm a lawyer doing title closing, if I'm an underwriter and I have a software system that I own, that is now technically illegal to be used in the same transaction in the district. If I'm a lender, I can't have my own affiliated title. Liam, so is that a new law, or just – I know these were all settlements. There was no suit, no precedents.

Were people not just afraid? We have precedents now because we all settled. So, okay, now everybody is on their P's and Q's because now they have to do what we want to do business in D.C., and there are a number of companies that have said, no, we're not going to do business in D.C. after this settlement, lenders and some others because they are worried about the Attorney General taking the same stance and going for a quick headline and extorting them for money, which is effectively what happened in, I would say, three of the five cases here. Two of the companies that they hit in the Modern, I had no issues whatsoever with D.C.

going after them. They were clearly undercapitalized, and Union and Modern were the two that were certainly not set up properly, certainly from the undercapitalization standpoint. What's the rule of thumb now for capitalization for a new joint venture? The rule of thumb is $100,000 minimum capitalization for one state if you're going to do this, and if you go in multiple states, you obviously want it to go higher. Those are the numbers I have been explicitly told by several state Attorney Generals, some folks at the Bureau, and some others in the regulatory world.

That's what they're looking for now. What are some other states' AGs? Everybody, the city's presidents and other Attorney Generals, different states may want to put a nickname for themselves? They could. I think that this one was so far out of left field that I think it's going to be contained to D.C., just the way that they've applied this Consumer Protection Act, and I don't see it.

If it's going to take effect in other states, New York would be one, Pennsylvania would be the two, and I do know that there is an enforcement action coming down the pipe, or there is one in process in Pennsylvania, not involving the title insurance industry, but involving affiliated businesses. That'll be a restful one, though. So I haven't seen or heard about any other Consumer Protection Act angles being presented, although I know that people have made overtures to those regulators in other states to try to get them to be enticed to take it. If a state is to take it, I would say it's probably going to be in a Democratic state. It's going to be one of the blue states.

I would not anticipate this at all in a red state. It pushes the envelope, and I'm talking about companies that are compliant and that are RESPA compliant versus the ones that are not RESPA compliant. I think it's just going to be D.C. I think you will probably see an increase in enforcement in the next administration, primarily because the CFPB in particular has been settling a lot of cases lately, a lot of cases. They settled one of my cases, Townstone, a few weeks ago, and they've been very busy settling as many as they can get right now because they know that some of these cases that they were involved in were so over the top that they would have never gotten approved under anyone with a functioning brain.

I think you're going to see a lot of enforcement coming back into the CFPB under the Trump administration, but it's going to be concentrated on RESPA, maybe some LOCOM, some other UDAP things. It's going to go back to the nuts and bolts of enforcement, the things that we saw in the last administration. It's going to go back to the nuts and bolts of enforcement. know that some of these cases that they were involved in were so, are so over the top that they would have never gotten approved under any, anyone with a functioning brain is the word I would use. I think that you're going to see a lot of enforcement coming back into the, back at the CFPB under the Trump administration, but it's going to be concentrated on RESPA, maybe some LOCOM, some other UDAP things.

It's going to go back to the nuts and bolts of enforcement, the things that we saw really up until around 2000 and I think after 2015, we really started seeing the Bureau really run roughshod over laws and trying to make their own sort of unique interpretations as the new enforcement part. So I think that's going to go away, but I do think that they're going to focus back on affiliated businesses. And, and you know what, it's a good thing. I don't have any issue with them focusing on affiliated businesses or marketing arrangements. There are a number of states that have moved into enforcement actions involving marketing and advertising right now, a large number of them.

And I think that that's healthy for the industry because it certainly protects one, the consumers, it protects the marketplace, keeps everybody honest. If you have one player that goes in and they're doing a whole bunch of really bad things, it distorts the entire marketplace and over time it creates a monopoly form, that's not good for anybody. The regulators serve a purpose, whether the companies be independently owned or they're affiliated. Everybody needs to play by the same rules. And with an affiliated operation, from my perspective, if it looks, smells, and feels like an independent company, and it's an affiliate, then you're going to be in good shape.

If it looks, feels, and looks like nothing more than just a strategy to get a hundred percent of the referrals, and there's no website, there's no employees, but those people need to hit them where they need to be hit and clean it up, that's my simple, quick answer. Is there a full-fledged title and escrow, ABAs, more scrutinized, or than just insurance issuance only? It's a great question. I haven't seen yes and no. I think some states, there may be a little bit more of a focus on it.

I'll use maybe in Arizona will be a great example for that, of what's going on there. They're having some enforcement actions. Arizona, if you don't know, Arizona was the Wild West of affiliated businesses, totally out of control. Not just for affiliated businesses, out of control across the border on everything. Everything was, it was Texas-sized over the top over there.

It's like Florida now? Florida, maybe Miami-sized, I think it actually topped the Miami market, which is crazy, which is crazy in itself, but they got some really good regulators in there. The new director of real estate, or the new commissioner for real estate for Arizona, Susan Nicholson and her assistant, Mandy Pete, they're terrific, absolutely terrific. They're going in and cleaning things up and they're holding the agents accountable. That's something that's rare.

You normally don't see the agents being held in that. And for the most part, a lot of these real estate commissions don't have the enforcement authority to go after the agents. So having, I think that this may set a little bit of a precedent for other states to follow what they're doing. As I said, I would put Susan Nicholson up there with Ivy Jackson and Bart Shapiro, as far as phenomenal RESPA heads, or just industry heads. They're reasonable.

They understand the business. They're not going to make it so complicated and convoluted that where they make up laws, it's about protecting the consumer and protecting the industry, which in Susan's case, she came from that industry. I do see some enforcement on that side from Arizona. Maryland, I think you may, there's some potential offshoots from DC in a couple of cases in Maryland. I'm not sure where Maryland's going to go.

They're not looking at it from a Consumer Protection Act sort of issue. They're looking at it strictly from a RESPA angle. Virginia, no. New Jersey has been very active recently in some different areas involving marketing and those sorts of enforcement areas. What about Texas?

TDI is its own little world. I've heard through the grapevine that TDA is starting to look at title owned or title agency only, or title issuing agent only models. Apparently that may be distorting a little bit of the marketplace over there. And so I could see them coming down hard, but that would be a good state where you may see some things popping up. I don't have anything in Texas right now, but it wouldn't surprise me.

The only thing that brought it up is just the number one markets in the country. Texas and Florida are both off the chart. What was it? South Carolina, North Carolina probably follows after that. Arizona.

But those states in particular, there's strong likelihood of something coming down the pipe in Texas. Florida, I've heard some similar things where they are looking at some problem children in that neck of the woods as well. I haven't got any yet, but I'm sure I'll... The one thing I love about Texas is everybody's afraid of TDI, which is the good thing. TDI is a whole rule.

A lot of rules and an even level playing field. It's great. They'll use a Texas-sized belt on you pretty hard. With the buckle. And that's not a place to play around, Texas.

There are some states you just do not mess around with. Texas, Nevada, California, Washington State, Oregon. Those states, you really, it's not a place to go push an envelope. So what are some of the most common mistakes title agents make regarding RESPA compliance and how can they avoid them? Capitalization is one of the bigger ones that I often see.

What's your rule of thumb? Anything below that, I typically won't represent somebody if they go below that. I just don't want to... I know what's going to keep you safe and I know what's not going to keep you safe. And when you go below that, I don't want to be on the hook for an E&O claim because you went below it.

I've talked to all of the other major RESPA attorneys. They're all on the same page on this $100,000 cap. We were just at RESPRO, the real estate settlement providers organization, a few weeks ago. And I know we had Holly and Rich Chandriano, Holly Bunning, Trip Riley, Jeff Harrell, who else do we have up there? We had Brian Levy.

And I think there was maybe one or two others. And the general consensus was $100,000. The other things that I see, affiliated business disclosure forms, that's the low hanging fruit. Those are often screwed up and those forms have to follow the model form. You can't just go make up a form, make up your own disclosure, include marketing information on there.

I have some advertising agreement with this. None of that belongs on there. If you own more than 1% of an affiliated business operation, you have to have your affiliated business disclosure form, model language to the T. Don't go mess around with it. Don't make it a marketing piece.

It's a simple form that no one reads. And even the CFPB enforcement attorneys don't make marks. We know nobody reads this, but we just want it for transparency. Can't blame them. Makes sense.

Transparent thing, piece of cake. People are going to click it and move on. But your ownership percentage is the other part in that affiliated business disclosure form. If I own 5% of a title agency and I'm a real estate agent or a real estate broker, I need to show I own 5% on that document. It can't just be Marks Owns Interest and XYZ title.

That's something that's really low hanging that the regulators will, if they're going to come after you and they have a couple of things on you, you can always migrate to the affiliated business disclosure form and try to settle that on. That's my piece. No employees is another one. That's a real problem. Dedicated full-time employees.

Let me say that. If you don't have a marketing and advertising budget, non-referral advertising and marketing budget, to be precise, the number I'm hearing from consistently across the country is 2% of annual revenue needs to go to non-referral source advertising and marketing. And if you're making $100,000, 2%, that's in line. You're not going to quibble about it. If you don't get any business, but you still have it codified and running and you're allocating 2%, you're showing that you're making a concerted effort to go out and generate business.

So if you don't generate it, you're not getting the return on it. You can obviously change that up, but they do want to see that a strong attempt at that to mitigate any sort of steering required issues that they could come up with. Think of another big one out there. Performing all the services is the other one. You really want to make sure that your company is performing the services and you're not just ferreting it out to the parent company with other low hanging fruit, kicking out members who don't send in business, don't do that.

Actually, I like when you have people that don't send in business because it just shows the regulator that, hey, we have some guy hadn't sent in business in 10 years. So you can't say it was all based on referrals. So it's a good protection defensive thing to have people that may not participate. It's not a bad thing. businesses, and you're not just ferreting it out to the parent company with other low hanging fruit.

Kicking out members who don't send in business. Don't do that. Actually, I like when you have people that don't send in business because it just shows the regulator that, Hey, we have some guy hadn't sent in business in 10 years. So you can't say it was all based on referrals. So it's a good protection defensive thing to have people that may not participate.

It's not a bad thing. If you have everybody that doesn't participate, that could be a bad thing. But certainly you want to make sure that if someone isn't participating, you're not putting undue pressure on them or kicking them out because they're not, that's just not, you're going to get yourself in trouble. The other parts, your pro forma, make sure it's beefy. Don't have some pro forma with just a couple of line items on it.

And then this, I'll steal this one from Chuck Kane. The E in email stands for evidence, the T in text stands for trouble. And I will say the S in social media stands for stupidity. So those three things right there will get you in trouble every single time. And no matter how, even if it's a joke and you text somebody and you read it, you don't know it's a joke.

If you're a regulator, you're reading it on its face value. So always remember what you're putting in print and even personal between you. Try not to get too on that. If it is, make sure you go, Hey, that's a RESPA violation. We can't do that.

Just make sure you clean it up. But the social media, you can't clean up. Social media is one of the things that is triggering quite a few enforcement actions lately from marketing, from joint ventures, from just basic RESPA things. But both on social media and book parties. Social media is a really dangerous thing.

When you're dealing with people that get overly excited with social media, they want to overshare. Sometimes that oversharing is not a good thing. Years ago, I had somebody that had a pickup truck and he posted, he actually donated. It was a Ford F-150. This was his marketing plan.

He gave the Ford F-150 to a real estate agent with his sign emblazoned on the side of it. So he's driving through town and this lady can drive wherever she wants, selling her real estate with the loan officer's name on it. And the real estate agent posted that to social media. It was bad enough that he was driving around town. Then she posted to social media.

That immediately triggered the regulators. Two seconds. They ran on top of this poor guy. It's legitimate marketing and advertising. In your mind it was, but the providing of the free car was not.

So it's things people do that they just don't think sometimes, but those are some hot button areas. Employees, former employees, ex-wives, ex-girlfriends, ex-spouses. That's the other area that a lot of these enforcement actions are triggered. You want to make sure that you're running a good, clean operation because if you do something and you're not a good person to your employee when they're departing or something, you can wind up getting yourself into a heap of trouble from a disgruntled employee or disgruntled spouse. Looking ahead, what trends or changes do you foresee in the regulatory environment that title professionals should prepare for?

I think the MLS lawsuit is going to be an interesting one. It's going to create a lot of consolidation in the industry and not just consolidation in the real estate brokerage space. It's going to create consolidation in the real estate agent space as well. And so where you may have had 10 agents before that were referral sources, maybe now they're six referral sources. So let's say four of them are out of the business.

That's four less places, four less companies that those agents would have placed a title order. I think you may see some consolidation in the title agency space, the title underwriter space. I talked to Pat Stone earlier this year, and as we're discussing this, the same thing on the MLS lawsuit, we have 32, 34 active title insurers in the United States. When this really plays out, I would be shocked if we didn't have 12 to 14, just because he sees that consolidation taking place. So I think the affiliated business part is where the industry is going to head, whether you like it or not.

It's going to be a full steam ahead and all companies are going to need it. I think you'll see it both in the property casualty insurance side, as well as the mortgage broker and mortgage lending side. That's one area that I see significant changes coming. I think on the lending side, I think based on how we, it's not a little bit title related, our Townstone financial case that we just settled with the CFPB last month, I think the CFPB was trying to utilize that case to open up Pandora's box to where they could go after the largest non-bank lenders and banks across the United States for the selection of title agents or their settlement agents, title insurance agencies. And they were going to hammer those title agencies if they had, and this would be like in the Virginia, the Indianapolis or Indiana marketplaces in particular, some others, where the title insurance rates deviate from underwriter to underwriter.

So, if I'm writing in Fort Wayne, Indiana as a title agent and I'm on one underwriter and Fort Wayne's a low-income neighborhood, I'm charging a higher price title underwriter. And then I go to, let's say, Carmel, Indiana, which is a higher net worth neighborhood. I charge the lower rate because it's more competitive. They were looking at utilizing ECOA, Equal Credit Opportunity Act, against those lenders for the selection using UDAP and also hitting with the UDAP violation for the selection of that title agent or that title underwriter in that marketplace for allowing them to engage in discriminatory pricing. That's still possible, I think, because of how we fought back in the Townstone case and how we wanted the district court, even though it got overturned at the Court of Appeals.

There were a lot of things in motion there that I would say will curtail the CFPB from pushing the envelope and creating enforcement actions where there was no reason for an enforcement action whatsoever. That was the most egregious case I've ever seen in my entire professional career in this industry. You accuse somebody of discrimination who's not discriminated, and it's win at all costs. And if we have to destroy his life and his family's life and his employees' lives, we're going to do it. In that case, they couldn't find a single email.

They couldn't find anything that was off-color. They made up five different statements. They actually cobbled together statements that weren't a full statement, basically parsing sentences together, come up with one to put into their complaint, which soundbites, basically. Yeah, but it was like clips of soundbites they put together to make it sound like it was one sentence. That shouldn't be allowed to happen.

It shouldn't be allowed to happen. Do you think with Republicans in office and having the White House, the Senate, and Congress going to cut down on regulation a little bit or loosen it a little bit? I think that the Townstone case is a case that I don't think you've heard the last of. I think that we're going to have Senate hearings on that, congressional hearings on the abuses involved in that case, which will stun people at a level that it'll shock people when they really hear what took place in that. Just absolutely stunning what took place.

From the enforcement side to the whole litigation part and how they achieved that. Unfortunately, that case was approved under the Trump administration. When he was in, Kathleen Craninger was the one that signed off on it, but she was being pressured internally and externally to get a fair lending case. I think this modern day redlining theory stuff, I think the Trump administration is going to pull back on that. I think the DOJ will pull back on some of that craziness.

All that does is it just makes it more expensive for homebuyers to buy a house. It adds unnecessary red tape, regulatory tape. And all I've seen is there's a disparity between African-Americans and Caucasians. It's gotten wider because it's made it more difficult to get loans to folks. That's the government's doing.

Is there discrimination here? I'm sure that there is discrimination and redlining out there. But you can't just go kick a company to try to make something. It's just wrong on many levels. What's the latest on the AOL attorney opening letter?

You think it's going to fade away? Is that something that's going to gain traction or still more authorities to be prepared for whatever outcome? The alternative title insurance products. I am hearing that Freddie and Fannie are going to kill it, that there's too much risk, too much uncertainty, too many unknowns. And there's a political.

Let's just say that there was politics involved in that, where you had people that. Do you think that's going to fade away? Is that something that's going to get traction or still more retaliation to be prepared for whatever outcome that. Yeah, the alternative title insurance products. I am hearing that Freddie and Fannie are going to kill it, but they're not going to, there's just too much risk, too much uncertainty, too many unknowns.

And there's a political, let's just say that there was politics involved in that where you had people that were in high level political positions that may have been sitting on board of directors for some companies that help facilitate. Exactly. So I think that is, it's not a question of when it's going to be announced or if it's going to be announced, it's just a question of what day it's going to be announced. What resources or programs would you recommend to title agents to look into deepen their understanding of RESPA and regulations and make sure they're compliant? To me, the absolute best place for RESPA compliance, knowledge, depth, whether you're an affiliated business or not, or even if you're doing marketing, is the real estate settlement providers organization.

There isn't a better organization anywhere in the country that really educates all facets of the industry. I've been going to it since 2003. What's the name of it again? The Real Estate Settlement Providers Council, RESPRO. Oh, RESPRO, okay.

RESPRO, yeah. Phenomenal organization. You can learn. Every time I go to that conference, I come out learning something new. And I can't say that about other conferences that I go to.

And that's a strong statement coming from me, but it's great to hear regulators. It's great to hear other attorneys that feel it's a more relaxed environment. So you get a much deeper understanding of where the regulators are coming from and what they're seeing on the ground. You don't get that from a 50-minute session at XYZ conference. And October Research is another great one.

But let me say that. RESPRO and October Research are probably my two top conferences. When we started the podcast, you talked about your background in technology and how your father was one of the very early adopters of digital realm and digitizing mortgage title and all of that. I'm a big advocate of just innovation and going digital, not only just for efficiency and also reducing costs. And I know lenders complain and moan, as we do, about making money and how the margins are very slim.

And it really shocks me how they're not pushing forward the efficiencies and the cost reduction in post-closing. That's massive. And I'm just shocked how they're not pushing into it. Yeah, I'm shocked at that as well. Look, the system that we put in place in 2003, I saw one other system that came close to it.

I don't even know if it's still in use. But outside that, I haven't seen any system that's even come close. And that was now 20 years ago. Technology and adoption take time. I have a client of mine that invented wireless prime cameras and wireless internet, point-to-multipoint wireless technology back in 2003.

It took maybe 12 years for that to get into the beginning phases of commerce where people started using it. Because the title industry, you have a lot of older folks, you had a lot of people that have been in the industry for a long time, that change is a disruptor internally to them. I'm more focused on lenders. Lenders drive what we do. When lenders tell you just how you have to do it and people adapt quickly, they change the code.

I think from the lender perspective, they're concerned about the data breaches. The data breach and integrating in with their system, that costs a lot of money for these lenders to integrate in. So if you're on Encompass or one of these other systems, it's not free. And so, I think that's a huge problem. It's not free.

And so while I agree with you, they should all be incorporating this. The price point for this integration should be a heck of a lot cheaper than what's out there currently, because you only have a small number of players. You have a lot of people that are trying to get into the space. There's capacity constraints. That just doesn't, I think it's probably the excuse that a lot of them use.

But the ones that are growing by leaps and bounds are the ones that really have adopted technology deep into their operation. The Rockets and Guaranteed Rate, they're way out of it. Yeah, Loan Depot. Those three are prime examples. There's some others too, prime lending.

You've got some that are really heavily integrated in with technology, but for the entire industry, there's just a lot of peak, there's a lot of parts, limited resources, and the costs, especially now that your volume is down, nobody wants to go invest in a new technology system or invest in some integration, unfortunately. To me, this is the best time to integrate. Exactly. What have, looking back at your career, what has been the most rewarding or impactful moments as a respite attorney? Most impactful moment is I had a, there was a consumer that she was a client, she was a corporate client, but she had purchased a home and they stole her identity and basically defrauded her, didn't pay off her loan payoff proceeds, and she had no idea.

This was at the time, the nation's largest private mortgage bank, I'll leave it that, I don't think I can say the name of it, but in conjunction with some other individuals, closing attorney maybe, or some others, they came in and absolutely destroyed her. She couldn't get a six pack of Budweiser on credit if she tried. She was working two full-time jobs, sweetest woman in the world. I didn't know how bad it was until she came into my office and she brought her two young daughters and the daughters came up to me and they started crying. I think she went to the bathroom or something and they were crying, thank you for taking care of my mom.

I know she's been under a lot of pressure. So she came in, she saw them crying and she realized, oh my God, they know what's going on. So we fought for two and a half years and most disgusting and vile cases where the defense attorneys were going after her sexual preferences and how many men, just stuff that had no bearing whatsoever, but they were doing whatever they could to intimidate her to drop the case, everything under the sun, including calling her up and saying, hey, do you know where your kids are? Because we're watching them right now at school. So this was a big piece and the company itself, I think at the time, I think it was the HUD OIG was investing for $2.3 billion worth of loan fraud.

She was the catalyst for that. We got her first settlement and she was living, renting a room with her two daughters from a friend of hers. She couldn't get an apartment. And her car had just broken down and she's having a tough time. We went and bought her a car, put a big bow on it and I told her, listen, I'm going to pick you and your daughters up and I have some place I'm going to take you.

So we took her to the car dealership. I might choke up a little bit and the poor kid started crying. It was a very, you realize she did the right thing. So it was a case not many people can take. I'm getting chills myself.

Yeah, it would be a phenomenal John Grisham novel. It'd be a phenomenal novel, just that case. You should write it. OK, I got to write operating agreements for affiliated businesses, but it would be you can use AI not to write that book. So this would be the ultimate catch me if you can.

Oh, and things that you would in a million years never expect. The unexpected popped out. Wow, it was wild. But that story needs to go and needs to be out there. But that's awesome.

So what keeps you passionate about your work and what motivates you to continue advocating for compliance in the industry? Great question. I like to help the industry. I like to educate the industry. I love seeing companies succeed.

I love seeing people succeed. Like that to me is super exciting. And just helping them get off the ground, that just there's something about that kind of gets me excited. On the flip side, I guess it wasn't until the Townstone case that I really got invested, that really just pulled out more of that fuel. Yeah, yeah, there was a lot of fuel for that case.

Still is. It will be until I'm probably dead. I can see it in your face. Yeah, it's just it was so over the top. Cases like that that I'll get every once in a while, they're very rare.

But if I get a case like that, it just fuels me to one, educate people in the industry as to what's going on and to help them out. Now, you do have companies that do things the wrong way. I don't mind going in and helping them organize and structure and get their eyes dotted and T's crossed. That's also very uplifting to me as well. So long as they take my advice, the ones that don't take my advice.

So do you have a favorite quote that resonates with your professional philosophy? No good deed goes unpunished. Love it. How about books? What are your favorite book?

Ah, that's. them out. You know, you do have companies that do things the wrong way. I don't mind going in and helping them organize and structure and get their I's dotted and T's crossed. That's also very uplifting to me as well.

So long as they take my advice. The ones that don't take my advice. So do you have a favorite quote that resonates with your professional philosophy? No good deed goes unpunished. Love it.

How about books? What is your favorite book? John Grisham's novels. Yeah, The Firm is probably one of my favorites. And I went to Tulane for undergrad.

So probably the connection there. So I am going to say on you to write that book. It's a wild story. I think USA Today did a big story. It has bones that will shunt me.

Maybe you should co-author it with John Grisham. I think he lives here in the DC area somewhere. I'm sure he comes back to New Orleans quite often. I see him at my old stomping grounds. When I was at Tulane, I actually bartended at Pat O'Brien's on Bourbon Street.

So I probably served him once or twice there. We're getting close to the end of our podcast today. Do you have any last words of wisdom? No matter how tough the market gets, just look around and see what the horizon looks like and companies will get through it. I know it's been a difficult time for a lot of companies the last couple of years.

And I do think we're going to be on that upturn. Is there light at the end of the tunnel? There's definitely light at the end of the tunnel. Doing things the right way, you can put your head down, sleep, and not worry about it. You can see some actions and some technology coming into place over the future.

The use of AI and enforcement actions, I think is going to dramatically speed up a lot of these enforcement cases. So I do think that some of the competitors that are out there that are really acting in a bad manner will be cleaned up. With that said, always good to meet your regulator, whether it's the states or the feds. Don't be scared of them. They're just people like you and I, and they like to hear what's going on in the industry.

They get to know you, so you're not this monster. Correct. They think you're out to get everybody. They all still think I'm the monster, but that's a different story. That's it for today's episode of the Tidal Agencies Podcast.

A big thank you to Mark Sterbko for sharing his invaluable insights on regulatory landscape and the future of compliance in our industry. Be sure to subscribe for more expert interviews and practical strategies to grow your business. I'll see you next episode. Thank you so much, Mark. Thank you, Mo.

I appreciate it. And that's a wrap on today's journey with Mo Shamil from the Tidal Agents Podcast, reminding you that mastering the art of innovation is key in the tidal industry's fast-paced world. If you're finding it tough to keep up with the changes and challenges, remember, you're not alone. Our calendar is open for you. Find the link in the show notes and let's connect.

Make sure to hit subscribe to not miss out on strategies that elevate and insights that empower. Together, we'll navigate the future of the industry. I look forward to our next meeting in the upcoming episode. Keep pushing, keep innovating, and see you in the next episode.