Yes. Providing space for a luncheon and free food for realtors should not be a problem, provided that you are not limiting attendance or favoring certain realtors based on their referrals to your institution.

The Real Estate Settlement Procedures Act (RESPA) regulations prohibit you from providing “any fee, kickback or other thing of value” in return for the referral of a settlement service on a federally related mortgage loan (a loan for 1–4 family residential real property that is not for a business purpose). 12 CFR 1024.14(b). We believe that providing a meal for realtors would be considered a “thing of value,” a broad term that includes “things” as well as payments of money, fees, commissions, royalties, etc. 12 CFR 1024.14(d). However, there is an exception for your “normal promotional and educational activities that are not conditioned on the referral of business and that do not involve the defraying of expenses that otherwise would be incurred by persons in a position to refer settlement services . . . .” 12 CFR 1024.14(g)(1)(vi). We believe that providing space and food for a luncheon would be considered part of your institution’s normal promotional activities, but you should ensure that your lenders are not limiting attendance to realtors that refer business to your institution.