Compensation & compliance, in plain English.
The most common question we get from professionals isn’t “does this help my client?” — it’s “can I participate without a compliance problem?” Here is exactly how it works: a fully-disclosed, arm’s-length arrangement, structured to your desk’s rules, where you never touch client funds.
How you’re compensated
A single, simple structure: a disclosed, arm’s-length referral. You introduce a client; a licensed party executes; you receive a referral fee that is disclosed to the client and documented.
- You are a connector, not a rep. You don’t sell a security, hold a Philippine license, or take on transaction liability. Low risk
- Written & disclosed. Compensation and any conflict are disclosed to the client in writing, per your regulator’s rules. On the record
- You never touch client funds. Ever. Money moves between the client and licensed settlement partners. Clean
- Structured to your desk. If your B/D or firm needs a specific form, we fit it — or operate with no fee at all. Flexible
The compliance framework
SEC Marketing Rule — Rule 206(4)-1
An adviser paid for a referral is a “promoter” and must provide written disclosure of the compensation and any conflict of interest. We build the arrangement to satisfy this — disclosure first, always.
RESPA — and why it usually doesn’t reach this
RESPA’s anti-kickback rules apply to federally-related mortgage loans on residential property located within a State. A Philippine property bought without a U.S. mortgage is largely outside RESPA’s scope — and we still hold to the stricter disclosure standard as a matter of practice.
Your professional body’s rules
Independence, fee-splitting, and referral rules differ by profession and state. We don’t ask you to bend any of them — we adapt the arrangement (including a no-fee, goodwill-only option) so it fits your obligations.
What you do — and what you don’t
✅ You do
- Recognize a suitable client and make a warm introduction.
- Keep advising the client on their U.S. tax, estate & insurance picture.
- Disclose the arrangement, per your rules.
❌ You don’t
- Hold a Philippine license.
- Touch, hold, or move client funds.
- Take on the Philippine transaction’s liability.
- Sell or recommend a security.
Educational, not legal or compliance advice. This page describes a general referral structure and is not a legal opinion on any professional’s specific obligations. Any compensation is offered only as a fully-disclosed, arm’s-length arrangement compliant with the professional’s own regulatory duties; consult your compliance department and licensed counsel before participating. Statutory references are current as of August 2026. © 2026 Van F. Wilson / Global Realtor 4a Cause.
