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RESPA Disclosure & Marketplace Notice

Effective: May 20, 2026

This document discloses how ClosingPack works, why we believe the platform complies with the Real Estate Settlement Procedures Act of 1974 ("RESPA") and related fiduciary obligations of real estate professionals, and what specific commitments we and our users make to keep it that way. This document is incorporated by reference into our Terms of Service.

Short version. Real estate agents on ClosingPack are compensated for placing vendors on a curated list. They are not compensated for any specific referral of business. The compensation is a flat monthly placement fee, never per-referral. We list only non-settlement services. Every booking page openly discloses the arrangement to homeowners. This structure is designed to be RESPA-clear by design.

1. What This Document Discloses

ClosingPack operates a marketplace in which:

  • Real estate agents publish curated lists ("packs") of recommended home-service vendors.
  • Vendors pay ClosingPack a flat monthly placement fee for each slot they occupy on an agent's pack.
  • ClosingPack pays the agent seventy percent (70%) of each placement fee. ClosingPack retains thirty percent (30%) as the platform fee.
  • Homeowners pay nothing to ClosingPack. ClosingPack takes no commission on services rendered by vendors to homeowners.

This document explains why we believe this arrangement is permissible under RESPA, the conditions on which that legality depends, and the obligations of all parties to maintain that compliance.

2. The Legal Framework

2.1 What RESPA Prohibits

Section 8(a) of RESPA (12 U.S.C. § 2607) prohibits any person from giving or receiving any fee, kickback, or thing of value pursuant to any agreement or understanding that business incident to or a part of a real estate settlement service involving a federally related mortgage loan shall be referred to any person.

RESPA defines "settlement service" specifically. As implemented in Regulation X (12 C.F.R. § 1024.2(b)), settlement services include mortgage origination, title insurance, escrow, mortgage-required home inspection, appraisal, credit reports, property surveys, hazard insurance, and attorney services involved in real estate closings.

2.2 What ClosingPack Lists

ClosingPack does not list any settlement-service providers. ClosingPack lists only providers of non-settlement home services, including but not limited to:

  • Painting, cleaning, junk removal, and moving services.
  • Landscaping, lawn care, tree service, and gutter cleaning.
  • HVAC service and repair, plumbing, electrical, and handyman services.
  • Roofing, flooring, drywall, and chimney service.
  • Pest control, carpet cleaning, power washing, and window cleaning.
  • Photography and home staging (when not part of a mortgage transaction).
  • Locksmith, appliance repair, and similar post-closing services.

Because none of these are settlement services as defined by RESPA, RESPA Section 8(a) does not prohibit compensation for referring business to them.

2.3 Why the Fee Structure Matters

Even where RESPA does not directly apply, structuring placement compensation as a flat monthly fee, rather than a per-referral commission, has important benefits:

  • The fee is paid for placement on a list, not for any specific referral. It is structurally equivalent to advertising or sponsorship, not a referral fee.
  • The agent's compensation does not change based on which homeowner hires which vendor, or whether any homeowner hires any vendor at all. The agent has no marginal financial incentive to favor any specific vendor in any specific recommendation.
  • The flat fee, combined with the platform's slot cap of three vendors per category per agent, makes the model robust against the reasoning that animates RESPA: the concern that hidden financial incentives can corrupt professional advice.

2.4 NAR Code of Ethics

For agents who are REALTORS (members of the National Association of REALTORS), Article 6 of the NAR Code of Ethics requires disclosure to clients of any compensation received from third parties in connection with referrals. ClosingPack is designed to meet this disclosure standard automatically.

3. Required Disclosure on Every Booking Page

Every ClosingPack booking page (the public-facing page where homeowners view an agent's vendor pack) displays a prominent disclosure that includes at least the following information:

  • That vendors listed on the page pay a monthly placement fee through ClosingPack to be listed.
  • That the agent who curated the page receives a portion of those placement fees.
  • That the agent receives no commission, referral fee, or other compensation based on whether the homeowner hires any specific vendor or the value of any services performed.
  • That the homeowner is free to use any vendor of their choosing, including vendors not on the list.

This disclosure is generated by ClosingPack and cannot be removed, obscured, or modified by agents.

4. Agent Obligations

Real estate agents who use ClosingPack agree to the following:

  • Automatic disclosure preserved. Every booking page displays a ClosingPack-generated disclosure to homeowners. Agents agree not to remove, obscure, or modify it.
  • Independent disclosure compliance. Agents are responsible for any additional written or signed disclosure their state's licensing rules, brokerage policies, or the NAR Code of Ethics may require, separate from the on-page disclosure. ClosingPack provides an optional template Vendor Recommendation Disclosure that agents may use at their discretion, but its use is not required by ClosingPack.
  • No settlement-service referrals through ClosingPack. Agents agree not to use ClosingPack to refer clients to any provider of settlement services as defined by RESPA.
  • No per-referral compensation. Agents agree not to accept any compensation from any vendor, in connection with the use of ClosingPack, that varies based on the volume or value of referrals directed to that vendor.
  • Compliance with state law. Agents agree to comply with all applicable state real estate licensing rules, fiduciary obligations, and disclosure requirements.
  • Curation as personal recommendation. Agents agree that vendors listed on their pack are presented as personal recommendations and that they will remove any vendor they no longer recommend.

5. Vendor Obligations

Home-service vendors who use ClosingPack agree to the following:

  • No settlement services. Vendors agree not to provide or advertise settlement services through ClosingPack.
  • No off-platform per-referral compensation. Vendors agree not to pay any agent any compensation, in cash or in kind, that varies based on referrals received through ClosingPack, beyond the platform's monthly placement fee.
  • Honest representation. Vendors agree that their business descriptions, license claims, insurance attestations, and service-area descriptions on ClosingPack are accurate and current.
  • Direct service relationship. Vendors agree that their service relationship with any homeowner referred through ClosingPack is direct between vendor and homeowner; ClosingPack is not a party to that contract.

6. ClosingPack's Operational Commitments

ClosingPack commits to operating the platform in a manner consistent with this disclosure:

  • We will not list providers of settlement services on any agent's pack, regardless of how categorized.
  • We will set monthly placement fees by service category, not by individual agent's referral volume.
  • We will limit each agent to a maximum of three vendor slots per service category, to preserve the curation that justifies the placement-fee structure.
  • We will display the disclosure described in Section 3 on every booking page, in a form designed to be visible before a homeowner engages with any listed vendor.
  • We will not modify the disclosure in ways that materially weaken it, and we will not allow agents to do so.
  • We will provide each agent and vendor with documentation of the compensation arrangement sufficient to satisfy applicable disclosure obligations.

7. Platform-Sponsored Vendors

ClosingPack may include "platform-sponsored vendors" on agents' packs by default. A platform-sponsored vendor is one whose monthly placement fee is funded by ClosingPack or by an entity that shares common ownership with ClosingPack, rather than by the vendor's own payment. These vendors are clearly labeled as platform-sponsored both on the agent's dashboard and on every booking page where they appear.

As of the effective date of this disclosure, ClosingPack's only platform-sponsored vendor is LoadUp, a nationwide on-demand junk removal company. LoadUp and ClosingPack share common ownership through Greg Workmon individually. LoadUp is included on every active agent's pack at the time of the agent's activation as a starter vendor.

Important characteristics of platform-sponsored vendors:

  • The platform-sponsored vendor's monthly placement fee is funded internally, not by an external third party paying for referrals.
  • Agents receive the same percentage share of the platform-sponsored vendor's placement fee as they would from any other vendor (currently seventy percent, 70%).
  • Agents may remove a platform-sponsored vendor from their pack at any time, in the same manner as any other vendor. Once removed, the platform-sponsored vendor is not re-added.
  • Platform-sponsored vendors are not settlement-service providers and do not provide any service that RESPA defines as a settlement service.
  • The booking-page disclosure clearly identifies platform-sponsored vendors and the common-ownership relationship.

ClosingPack maintains the platform-sponsored vendor designation to seed agents' packs with a credible starting recommendation and to reduce the cold-start problem that affects new agents. The structure is internal to the platform's common ownership and does not involve any third-party fee paid to or by the platform for referrals.

8. Acknowledgment

By using ClosingPack as an agent, vendor, or homeowner, you acknowledge that you have had the opportunity to read this disclosure and understand:

  • The platform involves a flat monthly placement-fee structure paid by vendors to ClosingPack;
  • Agents receive a portion of those fees;
  • No compensation flows in either direction based on whether any specific service is performed;
  • Settlement services are not part of the platform; and
  • ClosingPack may include platform-sponsored vendors on agents' packs, which are clearly labeled and may be removed by agents at their discretion.

9. No Legal Advice

This document describes ClosingPack's understanding of how the platform operates within the legal framework that applies to real estate referrals. It is not legal advice. Agents should consult their broker and, where appropriate, independent legal counsel regarding their obligations under their state's real estate licensing rules and any other applicable law. Vendors should consult independent counsel regarding their obligations as well.

10. Changes

This disclosure may be updated to reflect changes in law, regulatory guidance, or platform operations. If we make material changes, we will notify users at least thirty (30) days before the changes take effect.

11. Contact

For questions about this disclosure or about RESPA compliance:

ClosingPack LLC
Alpharetta, Georgia
Email: hello@closingpack.ai