Facebook Page Follow Up RESPA Note

After I posted this follow up to my business Facebook page, I received a message from Sonja Grant Wheeler:

Hello, we saw your article on National Mortgage News and have a concern about a potential RESPA violation. The $100.00 gift card giveaway can be construed as a "kickback"
RESPA Section 8 prohibits anyone from giving or accepting a fee, kickback, or anything of value for exchange for referrals of settlement service business involving a federally related mortgage loan. We would hate to see you have a problem with the CFPB. We recommend an attorney's opinion on your referrals.

I felt that the giveaway was not a violation but after receiving this, decided to look into it a bit further. We asked our compliance officer to review how I handled the first giveaway and we were told that it would violate RESPA if I am asking for reviews as this requires you to be a client to qualify for the giveaway.  

I promptly saw the light and will be doing future giveaways as a question that anyone can answer to win. It was suggested that I preface it with "Take my informational survey to be entered into a ………."