Effective Date: April 25, 2025

Offered By: Circle Home Loans, a division of Priority 1 Lending, LLC ("Circle")

1. Program Overview

Circle Points™ is a proprietary, post-closing marketing reinvestment system, built to support real estate agents who collaborate on closed transactions with Circle Home Loans.
Circle Points™ are non-cash, non-transferable marketing credits, redeemable only for Circle-managed business development services.

Important:

Points are earned only after a successful loan closing.

Points cannot be earned for referrals.

Participation is voluntary, and no referrals are required to qualify.

2. Earning Circle Points™

Agents can earn Circle Points™ through:
Active participation in a closed mortgage transaction (verified through documented collaboration: contract submission, buyer consults, closing attendance, etc.)

Attendance at approved Circle Home Loans webinars or educational events

Completion of onboarding activities after joining the Program

Circle Points™ are awarded after each successful closing at the sole discretion of Circle Home Loans LLC, based on verified collaboration and transaction completion. Points are designed to support your business growth and marketing success.

3. Redeeming Circle Points™

Circle Points™ may be redeemed exclusively for Circle-managed marketing services, such as:

Paid social media advertising (Facebook, Instagram, Google, Zillow)

Listing video production

Direct mail campaigns

Buyer event sponsorships

Local SEO services

Custom-designed marketing campaigns (for eligible tiers)

Important Rules:

Points may not be redeemed for cash, commissions, or personal gifts.

All services are managed and executed by Circle Home Loans' marketing team.

Co-branded marketing must adhere to fair market cost sharing under RESPA.

4. Badges & Recognition Tiers

Agents earn recognition badges based on accumulated Circle Points™:

Badge Level Total Points

🥉 Connector3,000 Points

🥈 Builder6,000 Points

🥇 Accelerator12,000 Points

💎 Partner Pro25,000+ Points

Badge perks may include early campaign access, dedicated marketing design support, or enhanced custom marketing options.

Thresholds and benefits are subject to change at Circle's discretion.

5. Program Governance & Discretion

Circle Points™ are awarded at the sole discretion of Circle Home Loans LLC.

Circle Home Loans LLC may modify, suspend, or discontinue the program at any time without notice.

Points expire 12 months after award unless otherwise stated.

Circle retains full control over the content and execution of marketing services delivered through Points.

6. RESPA Compliance Statement

Circle Points™ is fully designed to comply with Section 8 of the Real Estate Settlement Procedures Act (RESPA), HUD guidance, and CFPB enforcement practices.

Specifically:

Points are awarded only after a transaction closes.

Points are not tied to referrals, promised transactions, or steering activities.

Marketing execution is based on real, documented business activities — never on referrals.

Full compliance audits are conducted quarterly.

All agent participation is voluntarily documented through disclosure agreements.

7. Limitations of Liability

Circle Home Loans LLC and Priority 1 Lending, LLC are not liable for any direct, indirect, incidental, or consequential damages related to participation in the Circle Points™ program.

Circle makes no guarantees regarding marketing outcomes, lead generation results, or business growth.

8. Proprietary Rights & Intellectual Property

Circle Points™ is a proprietary business development system, created, owned, and exclusively offered by Circle Home Loans LLC.

All program structures, materials, educational assets, and branding are protected under intellectual property law.

Unauthorized copying, imitation, or confusion with Circle Points™ is strictly prohibited and subject to legal enforcement.

9. Disclosures and Agent Acknowledgment

Participation in Circle Points™ requires acknowledgment of the following:

I understand Circle Points™ are earned after closed transactions and not for referrals.

I understand that Circle Home Loans LLC controls the award, execution, and terms of the program.

I understand participation is voluntary and no future business obligations are created.

Agents are required to acknowledge these Terms & Conditions during onboarding, upon Points award, or prior to redeeming any marketing services.

For Compliance Questions or Documentation Requests:

Email: [email protected]

Circle Points™ Legal Compliance Addendum (Summary)

No Points for referrals (strictly post-closing only)

No cash value, no transferability

All marketing services comply with HUD, RESPA, and CFPB guidelines

Quarterly internal audits conducted

Agent disclosures signed and stored

Proprietary system IP protected nationally