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When can title companies give gift cards? Never, state says (The Real Deal)
The Real Deal, February 27, 2018
When can title companies give gift cards? Never, state says
“Question: When is a gift card not just a gift card? Answer: When it’s an inducement. ‘At the end of the year, giving gift cards to your referral sources, or having a big party — that’s not marketing,’ said Maria Vullo, superintendent of the state’s Department of Financial Services, speaking to an audience of lawyers on Tuesday at the New York City Bar Association. ‘That’s a gift,’ she said. ‘It’s an inducement.’ The chief insurance regulator was using the pulpit to offer a full-throated defense of a DFS crackdown on excessive marketing among title insurers. She said the new regulations — which took effect Feb. 1 after a slight delay — are modeled after regulations in other business sectors.”
