There’s no catch — and no, you don’t have to send us deals first. But to be upfront, we can’t invest heavily in a market until there’s some traction. Once we close a few deals together, we reinvest what we earn to help grow both sides — that’s the model. It’s not about asking for referrals upfront, it’s about earning them by showing you how we work first.

Our program is fully compliant with the Real Estate Settlement Procedures Act (RESPA) because it’s built around three key principles: No referral fees, no required transactions, and full transparency. We do not pay or accept compensation for referrals. Instead, our system—like Circle Points™—rewards agents only after a closed transaction, and only for actual services rendered (such as co-branded marketing, webinars, or educational participation). All value provided is documented, optional, and proportionate, ensuring compliance with Section 8 of RESPA. We also maintain a clear paper trail, written agreements when necessary, and never condition business on referrals—ever. This isn’t about buying business. It’s about building mutually beneficial partnerships where both sides win—and do so ethically.

✅ 1. Clear, Upfront Disclosures Circle provides transparent terms on loan programs, rate options, and fees at the beginning of the client relationship. We use tools like Loan Estimates, mortgage double-checks, and Circle Buyer Readiness Scores™ to eliminate surprises. Agents and borrowers know what’s being offered—and why.

✅ 2. Ethical Profit Reinvestment Rather than hiding profits or using teaser rates, Circle reinvests a portion of lender profit back into the agent’s brand and consumer experience—in full view of all parties. This creates alignment: when we win, our partners and clients do too.

✅ 3. No Hidden Agendas No referral fees, no kickbacks, and no quid pro quo. Circle Points are earned only after closed transactions and only for services actually performed—compliant with RESPA. Our pitch isn’t “send us deals.” It’s “let us protect your client, earn trust, and then we’ll earn the business.”

✅ 4. Consumer Empowerment Through Choice We protect the client’s right to choose their lender—no pressure, no conditions. We encourage second opinions via Mortgage Protection Checkups, empowering consumers to make informed, confident decisions. This aligns with CFTD’s principle of reducing information asymmetry.

✅ 5. Full Transparency in Co-Marketing Any co-marketing activity is documented, voluntary, and proportionate to actual value received, in line with HUD guidance. We provide written agreements, real marketing deliverables, and agent-facing dashboards to track performance and use of funds.

In most cases, no. Circle Points™ does not require an AfBA disclosure unless you have an ownership stake or financial interest in the partner you're working with (e.g., title, escrow, insurance, or real estate company).

Here’s the breakdown:

✅ You DO NOT need an AfBA disclosure if: You're simply rewarding real estate agents with marketing value (post-closing) based on real, documented services. There is no shared ownership between Circle Home Loans and the agent’s brokerage or any other settlement service provider. You are not requiring the use of a specific title, escrow, or insurance company that you own or have a stake in. Circle Points™ are used for things like: Facebook ads Just listed postcards Video production Local SEO

✔️ These are marketing services, not settlement services—so AfBA does not apply.

🚨 You MAY NEED an AfBA disclosure if: Circle or Priority 1 Lending owns or has a financial interest in a: Title company Escrow service Insurance agency Realtor team/brokerage And you direct business to those companies as part of the transaction In that case: You must disclose the relationship in writing using a standardized AfBA form You must state that consumers are not required to use the affiliate You must offer alternative options

We help you grow by doing what most lenders won’t — we reinvest into the business we build together. That means running local marketing, booking buyer webinars, creating agent-branded funnels, and even helping re-engage your past clients. Our process drives serious buyers to you, and our team closes them fast. The more we close, the more we put back into your market. It’s a true partnership — not just talk.

Every lender says they have great service, fast closings, and good rates — that’s the baseline. What makes us different is what happens after the closing. We reinvest our profits to drive more clients to our agents. We host webinars, build marketing funnels, offer agent tools, and even book you meetings — all funded from what we close together. No one else does that at scale. We don’t ask for handouts — we build real partnerships that grow your business

Fair question — and honestly, it’s one we hear a lot. The reason is simple: most lenders aren’t willing to share margin or reinvest into agents the way we do. It’s easier to just collect referrals and move on. We took a different path — we built Circle quietly, tested it, and proved it works before scaling. You haven’t heard of it because we haven’t needed to shout. Now that we’re expanding, you’re hearing about it early

Yes — but only after we’ve closed business together. We don’t ask for upfront referrals, and we don’t promise the world without results. Once deals start closing, we reinvest the profits back into your market — through co-branded ads, webinars, client funnels, and even scheduling buyer or agent meetings for you. It’s not theory — it’s part of our business model. When you win, we win, so it only makes sense to fuel that growth together

We don’t hand out leads with strings attached — but yes, we absolutely help you get them. Once we’ve closed a few deals together, we use part of our profit to run buyer webinars, re-engage your past clients, and drive traffic through custom funnels and marketing. You stay front and center, and the activity we generate leads to real conversations, not cold leads. It’s a system we’ve built to grow together — not just a lead drop

Yes — once we’ve closed a few deals together, we can help amplify your brand. That includes co-branded funnels, social media ad templates, email campaigns, and even webinar promotions. We focus on positioning you as the expert while we handle the backend. It’s not about just slapping a logo on something — it’s about building you up as the go-to agent in your market

No, you don’t have to co-market with us to benefit. Everything we do — fast closings, real-time updates, pre-approval guarantees, buyer readiness scoring — is built to make you look good whether we co-market or not. But if you want to amplify results together, we can explore compliant co-branded marketing once we’ve closed some business. It’s optional, never required

Our webinars are high-converting, professionally run, and built to educate buyers while positioning you as the trusted local expert. We handle the setup, ads, follow-up, and presentation — you just show up (if you want to). Topics include first-time homebuyer secrets, how to win in today’s market, and strategies to save thousands. They generate real leads, not just views — and we loop you in on every attendee who’s ready to move

Referral-based business is where we started — and where we still excel. For over 15 years, we built our reputation by serving agents at the highest level, becoming top-ranked originators on Scotsman Guide strictly from agent referrals. That doesn’t happen without great communication, fast closings, and consistent follow-through. We’ve just added a direct-to-consumer engine on top of that — but the referral side is still at the core of everything we do

"We’ve been in the mortgage business for over 15 years. In that time, we’ve closed thousands of loans, built long-term agent partnerships, and invested over $5 million into direct-to-consumer marketing. Our team has seen every kind of market — and we’ve used that experience to create a model that not only closes loans fast, but actually helps agents grow. Circle Home Loans is the result of everything we’ve learned, refined, and proven to work.