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Commission ratifies advisory opinion: referral gift cards tied to rentals not permissible for licensed firms
Summary
The commission voted to adopt an advisory private‑letter ruling finding a proposed $50 referral gift‑card program — where firms would compensate unlicensed referrers with gift cards and recover part from agents’ commissions — is not permissible under current rules except in narrow closing or broker‑open contexts.
The Tennessee Real Estate Commission unanimously approved an advisory private‑letter ruling Dec. 17 declaring the referral program described in a submitted attorney’s request would not be permissible under current rules.
Anna Matlock read the submitted proposal from a firm that described a referral program paying $50 Amazon gift cards to people (some unlicensed) who refer tenants who sign leases. Matlock told commissioners that, under existing interpretation and recent rule language, "gift cards are only permissible in two…
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