Referral playbook

Is It Legal to Get Paid for Referring a Contractor?

The FindAZPros TeamPhoenix, AZ contractor directory22 min read

Yes, in most cases. A referral fee for non-settlement home services such as HVAC, roofing, or plumbing generally falls outside RESPA Section 8 when the referral is kept separate from any real-estate or mortgage transaction and is properly disclosed. The real constraint is usually state contractor-licensing law and disclosure, not RESPA. Below is the plain-English version for property managers, realtors, and well-connected locals, with the primary law cited so you can check it yourself.

Important

This article is general information, not legal advice. Referral-fee rules turn on the exact facts of your situation and your role. Before you accept any referral fee, confirm your specific case with a licensed attorney or your state licensing board. Nothing here says contractor referral fees are always legal. The point is to show where the lines are.

If you manage property, sell real estate, or are simply the person everyone in your neighborhood texts when their air conditioner dies, you have referral value. You already send work to contractors for free. The question that stops most people from getting paid for it is a fair one: “Is it even legal to take a fee for referring a contractor?” The honest answer is that it depends on three things, what kind of service you are referring, whether a mortgage or real-estate transaction is involved, and whether you disclose the arrangement. Get those right and a referral fee is a normal, legitimate way to earn income. Get them wrong and you can land in the most heavily enforced corner of federal real-estate law.

What is RESPA Section 8, and does it apply to home-services referrals?

Short answer: RESPA Section 8 bans kickbacks only for settlement services tied to a federally related mortgage loan, so it almost never reaches a standalone HVAC, roofing, or plumbing referral.

Most of the fear around referral fees traces back to one federal law: the Real Estate Settlement Procedures Act, or RESPA. Its anti-kickback provision, Section 8, is the rule people are usually worried about, and it is far narrower than its reputation suggests.

Definition

RESPA Section 8 is the federal anti-kickback rule that bars giving or accepting a fee, kickback, or thing of value for referring settlement-service business that involves a federally related mortgage loan.

The regulation that implements it, 12 CFR 1024.14(b), states the prohibition directly:

“No person shall give and no person shall accept any fee, kickback, or thing of value pursuant to any agreement or understanding, oral or otherwise, that business incident to or part of a settlement service involving a federally related mortgage loan shall be referred to any person.”

— 12 CFR § 1024.14(b)

Read that closely and you will notice it does not say “no one may ever be paid for a referral.” It bars fees for referring settlement-service business that is part of a deal involving a federally related mortgage loan. Two specific conditions have to be present at the same time. The phrase “thing of value” is interpreted broadly. It can reach beyond cash to gifts, trips, discounts, and other perks, which is one reason the law has such a fearsome reputation. But the breadth of what counts as a payment does not change what kinds of referrals the law actually covers.

Definition

A settlement service is a service connected to a real-estate closing. RESPA’s implementing rule, 12 CFR 1024.2(b), defines it through an enumerated list: loan origination, processing and underwriting, title searches and title insurance, document preparation, appraisals, credit reports, real-estate brokerage services, and the like.

Here is the part that matters for home services. That enumerated list is about getting a property bought, financed, and closed. It does not include fixing an air conditioner, replacing a roof, repiping a bathroom, installing windows, or putting panels on a house. HVAC, roofing, plumbing, window, and solar work performed for a homeowner, especially after they already own the home, are simply not settlement services as RESPA defines them. You can read the enumerated definition yourself at 12 CFR 1024.2(b).

Why are home-services referral fees usually outside RESPA?

Put the two triggers together and the logic is straightforward. For RESPA Section 8 to apply, the referral has to be (1) for a settlement service that is (2) part of a transaction involving a federally related mortgage loan. A referral to a roofer for a homeowner who needs a new roof is neither. There is no settlement service, and there is no mortgage loan being originated. The transaction is a homeowner hiring a contractor to do repair or improvement work, which has nothing to do with a closing.

Two further points reinforce it. RESPA does not apply at all when there is no federally related mortgage loan, an all-cash purchase, for example, falls outside its scope entirely. It also exempts purely commercial or business-purpose loans (see 12 CFR 1024.5(b)), so even when a transaction is nearby, the federally-related-mortgage trigger may be missing. And the regulation contains an explicit safe harbor: Section 8 does not prohibit payment for goods or services actually performed, as long as the payment reasonably reflects fair market value. Referring a job, then doing the work, then being paid for that work is exactly the kind of arrangement the safe harbor protects.

The honest hedge, and the reason disclosure discipline matters, is that you can pull an otherwise-clean referral back into RESPA’s orbit if you bundle it with a covered transaction. If a fee is structured as a reward for steering a buyer toward a particular lender, title company, or settlement service as part of the deal, the analysis changes. The takeaway is not “home-services referrals are automatically fine,” it is “keep the referral separate from any mortgage or real-estate settlement, and you stay on the right side of the line.”

What is the difference between a referral fee and a kickback?

This is the distinction the entire topic turns on, and it is worth stating plainly: a referral fee can be perfectly legal, while a kickback is illegal, and the difference is not the dollar amount, it is the structure.

Definition

A referral fee is disclosed compensation for an introduction, or for a service actually performed, paid at fair market value and kept separate from any covered transaction.

Definition

A kickback is undisclosed compensation for steering business, typically tied to a settlement service in a mortgage transaction, hidden from the customer, and not matched by any real service performed.

Three tests separate the two in practice:

  • Disclosure. A referral fee is disclosed to the people it could affect; a kickback is hidden. Disclosure is the brightest line of all.
  • Separation from a covered transaction. A referral fee for non-settlement work sits outside any mortgage or real-estate settlement; a kickback is woven into one.
  • Value for value. RESPA’s own safe harbor protects payment for goods or services actually performed at fair market value. A fee that corresponds to a real introduction or real work is defensible; a payment for nothing but steering is not.

Run any arrangement through those three tests. If it is disclosed, separated from a settlement, and reasonable for what was actually done, you are describing a referral fee. If it is hidden, bundled into a deal, and paid for nothing but a nudge, you are describing a kickback, no matter what the paperwork calls it.

What does a compliant referral disclosure look like?

Because disclosure is the line, it is worth getting concrete about what “disclosed” actually means. You do not need a lawyer to write a sentence, though you should have one review your template if referrals become a real income stream. A workable disclosure is short, in writing, and given before the work is booked.

A compliant referral disclosure generally includes:

  • That a fee exists. State plainly that you may receive a referral fee if the homeowner hires the Pro you refer.
  • Who pays it. Make clear the fee comes from the platform or the contractor, not as an added charge to the homeowner.
  • That the choice is theirs. The homeowner is free to use anyone; your referral is a recommendation, not a requirement.
  • Separation from any transaction. If you are an agent or manager, note that the referral is separate from any real-estate transaction or your management duties.

A plain-English version a property manager could text or email is: “Heads up, I refer maintenance work to licensed pros through a referral program, and I may earn a referral fee if you hire them. It does not cost you anything extra, and you are free to use anyone you like.” That single sentence, kept on file, is much of the distance between a clean referral fee and a problem.

One structural advantage of referring through a marketplace is that the fee is paid by the platform out of a success fee owed by the Pro, not added to the homeowner’s bill, which makes the “who pays it” part of your disclosure simple and true.

Why are property managers the cleanest, highest-volume affiliate profile?

Short answer: their referrals are maintenance-driven and non-transactional, they already earn vendor income, and the one rule they must follow, disclosure, is easy to satisfy.

If RESPA is mostly about transactions, then the people whose referrals are least entangled with transactions are in the strongest position. That describes property managers almost perfectly. A property manager is not closing a sale when the water heater fails in unit 4. They are arranging maintenance. The referral is operational, recurring, and completely decoupled from any mortgage settlement.

Property managers also already operate ancillary-income programs. Vendor referral arrangements, maintenance markups, and preferred-vendor relationships are a normal part of how the industry earns beyond the management fee. Adding a clean, disclosed contractor-referral stream is an extension of something most management companies already do, not a new and exotic practice.

Arizona adds a wrinkle worth its own treatment: a property manager here is almost always a real estate licensee, which brings the ADRE conduct rules into play on top of everything in this article. We work through the disclosure standard, the conflict rule, and the structures that survive an audit in the Arizona property manager’s guide to contractor referral income.

And the volume is real. Maintenance demand is continuous in a way that transactions never are:

  • Recurring, not one-time. A managed portfolio generates HVAC, plumbing, roofing, and turnover work month after month, every unit is a perpetual source of jobs.
  • Non-transactional. Because the work is maintenance rather than a sale, the RESPA settlement trigger is simply absent.
  • Already trusted. Owners and tenants already ask the manager “who should I call?” The manager is just monetizing a recommendation they were giving away.

The single rule a property manager must respect is disclosure. A manager typically owes fiduciary or contractual duties to the owners they serve, and the line between a legitimate referral fee and an impermissible kickback is whether the arrangement is disclosed and kept separate from the manager’s paid management duties. Disclose the relationship, keep it out of the management contract’s scope of paid services, and the income is clean. Property managers already run paid vendor-referral and markup programs as a normal part of the business, so adding a disclosed contractor-referral stream is an extension of what they do, not a new practice. The structural advantage of a disclosed, completion-based referral is that it satisfies the disclosure test by design.

This is exactly why FindAZPros treats property managers as the primary partner profile. If you manage homes in metro Phoenix, you can refer the maintenance work you already coordinate and earn on every completed job , without touching anything that looks like a real-estate settlement.

Can realtors take contractor referral fees, and where is the RESPA risk?

Realtors can refer contractors and be paid for it, but this is where RESPA risk actually concentrates, so the structure matters more. The direct answer: a contractor referral that is decoupled from the real-estate transaction is generally fine, while a fee that is tied to, conditioned on, or bundled into the deal or its financing is where Section 8 exposure lives.

The practical distinctions:

  • The risk hinge is the transaction. A referral fee that functions as a reward for steering a buyer toward a settlement service as part of closing is the classic RESPA problem. A referral to a roofer six months after closing is not.
  • After-closing, decoupled referrals are lower risk. The cleanest realtor referrals happen when the deal is done and the recommendation is just one professional helping a homeowner with maintenance.
  • Real-estate referral fees are a different animal. Agent-to-agent referral fees, paying another licensed agent a negotiated share of the commission for sending a buyer or seller, are governed by real-estate license law and require a license. That is not the same thing as a contractor referral, and the two should not be confused.

Disclosure has become the flashpoint in 2025 and 2026 as scrutiny of agent compensation has increased. The safe posture for an agent is the same discipline a property manager uses: disclose the arrangement, keep contractor referrals separate from the settlement, and when in doubt, ask a real-estate attorney. Agents who want a simple, defensible structure tend to prefer maintenance referrals precisely because they sit so far from the closing table.

What does Arizona law say about referral compensation? (A.R.S. 32-2155 and 32-2101)

Federal RESPA is only half the picture. State law governs who may be paid for real-estate activity, and Arizona is specific about it. The key statute, A.R.S. 32-2155(C), makes it unlawful for a broker to pay compensation for licensed real-estate broker acts to a person who is not licensed at the time the service is rendered. You can read it at A.R.S. 32-2155.

The decisive question is what counts as a “broker act.” Arizona answers that in A.R.S. 32-2101, which enumerates the activities that require a real-estate license, essentially selling, leasing, exchanging, and managing real estate for others for compensation. The full definition is at A.R.S. 32-2101.

Referring a homeowner to an HVAC company or a roofer is not on that list. It is not selling, leasing, exchanging, or managing real estate. It is recommending a tradesperson for repair or improvement work. Because a contractor referral is not a licensed real-estate act, Arizona’s prohibition on paying unlicensed people for broker acts does not bar it. Arizona’s licensing rules consistently attach to real-estate activity, selling, leasing, exchanging, or managing property for others, not to recommending a contractor for repair work.

This opens a genuinely underappreciated door: the well-connected local who is not licensed at all. Real-estate license rules govern referring real-estate business, not contractor referrals, so a trusted neighbor, a community-group organizer, or a handyman who is constantly asked “who do you use?” can legally earn a contractor referral fee where they could not be paid for referring real-estate business. There is one corollary for property managers specifically: keep your contractor-referral income separate from the paid management services you are licensed or contracted to perform, so the two never blur.

Why are home inspectors generally barred from contractor referral fees?

It would be convenient to tell home inspectors they can monetize their referrals too. They cannot, and we will say so plainly rather than sell a path that does not exist. Home inspectors are generally prohibited from accepting referral fees from the contractors they recommend.

The barrier is ethics and licensing, not RESPA. InterNACHI’s Code of Ethics, the standard the largest inspector association holds members to, requires inspectors to protect the independence of their inspection, prohibits compensation that would compromise it, and bars inspectors from performing repairs on a home they inspected for 12 months. Read alongside the broad conflict-of-interest rules many states impose, the industry norm treats accepting a contractor referral fee as incompatible with an inspector’s independence. You can review the association’s standard at InterNACHI’s Code of Ethics.

The reason is structural. An inspector’s value is independence. A homeowner needs to trust that the defects the inspector flags are real, not a sales funnel for a contractor paying for the lead. Allowing an inspector to profit from the very repairs they recommend poisons that trust. So if you are an inspector, treat paid contractor referrals as off the table, and route the opportunity instead to the people who can take it cleanly: property managers and well-connected locals.

Can you be sued for referring a contractor who does bad work?

The practical worry behind every referral is not only “is the fee legal?” but “what happens to me if the contractor does a bad job?” For a property manager or agent, your reputation is the asset, and a botched referral can cost far more than any single fee earns. The reassuring part is that the same structure that makes a referral fee clean also limits your exposure.

In general, simply recommending a contractor does not make you legally responsible for that contractor’s work. The Pro is an independent business that carries its own license and insurance. Your risk rises when you over-promise (guaranteeing results), when you have a financial interest you hid, or when you refer someone you knew or should have known was unlicensed or uninsured. Each of those is avoidable.

The protections that matter:

  • Refer licensed, insured Pros. When the contractor holds a current AZ ROC license and carries insurance, their coverage, not your wallet, answers for the work. Checking the license on the state registry is the single biggest risk reducer.
  • Disclose, and do not guarantee. Recommend; do not warrant the outcome. Disclosure plus modest language keeps you in the role of a helpful referrer rather than a guarantor.
  • Use an accountable, exclusive channel. One accountable Pro per job, on a platform that re-matches or escalates if something goes wrong, means a problem has an owner and a resolution path, instead of a homeowner left stranded among competing bidders.

This is why the license check is not a marketing nicety. A referral program that reviews every listing by hand, puts the license number in public view, and sends one accountable Pro per job is protecting the referrer’s reputation as much as the homeowner’s home.

How does an exclusive, pay-on-completion referral actually pay you?

Knowing a referral fee is legal is one thing. Knowing it will actually be paid, and paid fairly, is another. This is where the structure of the referral program matters as much as the law, because the structure is what protects both your reputation and your check.

Definition

A success fee is a fee owed only when a job is actually completed, not a charge for a lead, a click, or an introduction. No completed job, no fee.

Definition

An exclusive lead is a referral sent to exactly one Pro, never resold to competitors. The Pro you refer the homeowner to is the only one who receives that job.

In the model FindAZPros uses, the flow is simple: you refer homeowner demand you already encounter, a listed Pro does the work, and a fee is owed only when the job completes. You earn 50% of that fee. The fee itself is not a rate card, each company chooses at sign-up what a closed job is worth to them, and a person handles every match, so a referral never gets lost in an automated queue and your payout is settled with you directly.

Because the numbers should always come from one place, here is the representative example we use across the site. On a $10,000 job at an illustrative 10% success fee (about $1,000), your 50% share is roughly $500, paid after the job closes. That figure is illustrative only; the real fee is whatever the company chose at sign-up, which is the honest way to describe a price set with real contractors rather than guessed at.

Want to sanity-check what your own referral volume could earn? Count the jobs you already direct in a year, then send your first one, the 50/50 split is the standing deal.

How is this different from Angi, Thumbtack, and HomeAdvisor lead-gen?

It helps to contrast a referral with the lead-generation marketplaces most contractors already know, because the difference is exactly what makes a referral worth paying for. On pay-per-lead platforms, a contractor buys a contact upfront, that contact is frequently sold to several competitors at once, and most of those contacts never become jobs. The referral model inverts all three of those properties.

Angi / HomeAdvisor (pay-per-lead)~$135 cost per lead*SharedYes, to severalUpfront, per lead
Thumbtack (pay-per-lead/quote)Per lead or quoteSharedYesUpfront, per lead
Exclusive referral (FindAZPros)$0 per leadExclusive (1 Pro)Never resoldOnly after the job completes

*Referral cost-per-lead averages about $52 versus roughly $135 for HomeAdvisor and Angi, per Siana Marketing. For the full per-lead pricing breakdown across Angi, Thumbtack, and HomeAdvisor, see our companion guide: Contractor Lead Costs in 2026.

Three numbers explain why exclusivity changes the math for everyone in the chain:

  • Shared leads are resold. Marketplace leads are commonly sold to several contractors at once (the per-platform detail is in our lead-cost breakdown), which means the homeowner gets a wave of competing calls and no one wins on service.
  • Shared leads rarely close. Independent comparisons put close rates for shared marketplace leads under 10% (Siana Marketing), while exclusive and referral leads convert far better because there is no race and the introduction carries trust.
  • The model can be penalized when it misleads. In 2023 the U.S. Federal Trade Commission ordered HomeAdvisor to pay up to $7.2 million for deceptively marketing the quality and source of its leads to home-improvement businesses.

For an affiliate, exclusivity is what makes the referral safe to put your name on. When you send a homeowner to a single accountable Pro instead of into a bidding pool, the homeowner has a good experience, the Pro values the introduction, and your relationship, the actual asset, is protected. That is also why FindAZPros is a two-sided marketplace: the same exclusivity that earns you a clean referral fee is what attracts serious Pros, who can join on the contractor side and pay only when a job is done.

How do you start earning referral income the RESPA-safe way? (5 steps)

Pulling it all together, here is the disciplined, low-risk path from “I refer contractors for free” to “I earn a clean, disclosed referral fee.”

  1. Confirm your profile is clean. Property managers and well-connected locals are the strongest fits; realtors should keep referrals decoupled from any transaction; home inspectors generally cannot accept these fees. Keep referral income separate from any licensed real-estate or management duties.
  2. Disclose the referral relationship in writing. Tell the homeowner (and, if you are a manager, the owner) that you may receive a referral fee. Disclosure is the single most important habit. It is the line between a legitimate fee and a kickback.
  3. Decouple the referral from any real-estate or mortgage transaction. Keep contractor referrals out of the settlement, the financing, and the deal. Maintenance and repair referrals are the cleanest because they have no transaction nearby.
  4. Refer through a registry that puts the license in public view. Send the job to a Pro whose AZ ROC license number is on the listing for anyone to check, on a platform that sends one Pro per job rather than reselling the lead. This protects the homeowner and your reputation.
  5. Get paid a success fee only when the job completes. Tie your income to outcomes, not contacts. You earn when the work is finished, settled with you directly after the job closes.

That is the entire model. If you already field “who should I call?” requests in metro Phoenix, you can become a referral partner and start earning on referrals you are currently giving away for free.

One more thing: are contractor referral fees taxable, and will you get a 1099?

Legal and taxable are different questions, and the answer to the second is yes. Referral income is ordinary income. If a business pays you $600 or more in referral fees in a calendar year, it will generally issue a Form 1099-NEC, and you are responsible for reporting the income whether or not a form arrives. Practically, that means keeping simple records of each referral and the fee paid, and, if referrals become a meaningful income stream, talking to a tax professional about estimated taxes and whether to operate through an LLC. None of this makes the income harder to earn; it just means treating it like the real business income it is. The full version of this, the $600 threshold, what to do when no form arrives, and the deductions that come with treating it as a business, is in do you pay taxes on contractor referral fees.

Phoenix and Arizona market context for referral partners in 2026

The reason this model works especially well in metro Phoenix is demand depth. Arizona’s climate and housing stock generate relentless, recurring home-services work: extreme summer heat is brutal on HVAC systems and roofs, and a large base of homes means a continuous stream of plumbing, window, and solar projects. Maintenance demand here is not seasonal noise. It is a baseline.

Property management in the Valley is correspondingly deep. Large local firms manage hundreds of single-family homes apiece, and every one of those doors is a perpetual source of maintenance jobs that has to be routed to someone. That is precisely the demand a referral partner can send in. FindAZPros treats the trades neutrally, 23 of them, from HVAC and roofing to plumbing, concrete, and solar, and lets real demand decide where to concentrate, which means a referral partner is not boxed into a single trade.

Sending a job takes a couple of minutes on the Refer & earn page. And because every match is handled by a person and every listing is reviewed by hand and shows its AZ ROC license number, the homeowner you refer can see exactly who they are getting, which is ultimately what keeps your referrals worth making.

The bottom line

Is it legal to get paid for referring a contractor? In the great majority of home-services cases, HVAC, roofing, plumbing, and similar work kept separate from any real-estate or mortgage transaction and properly disclosed, yes. RESPA Section 8 is narrower than its reputation, Arizona’s license rules govern real-estate acts rather than contractor referrals, and the practices that keep you safe (separation and disclosure) are simple to follow. Property managers and well-connected locals are the cleanest, highest-volume profiles; realtors can participate with care; inspectors generally cannot. Verify your own situation with an attorney, then put your network to work. FindAZPros gives you the structure to do it well, refer a job, we make one hand-picked intro, and you earn 50% of the fee when it closes.

Sources

Frequently asked questions

Can a property manager legally earn a referral fee for sending home-services jobs to a contractor in Arizona?
Generally yes. A referral fee for non-settlement home services such as HVAC, roofing, or plumbing, kept separate from any real-estate or mortgage transaction and properly disclosed, typically falls outside RESPA Section 8 (12 CFR 1024.14). Property managers owe fiduciary disclosure, so the key is to disclose the arrangement and keep it separate from your licensed property-management duties. This is general information, not legal advice; consult an attorney for your situation.
Does RESPA Section 8 apply to HVAC, roofing, or plumbing referrals?
Usually not. RESPA Section 8 applies only when two things are both present: a settlement service AND a federally related mortgage loan (12 CFR 1024.14). HVAC, roofing, plumbing, and other after-closing home-improvement work are not on RESPA’s enumerated list of settlement services (12 CFR 1024.2(b)), so a referral fee with no mortgage-settlement connection generally sits outside the law’s scope.
What are the penalties for a RESPA Section 8 kickback violation?
Under 12 USC 2607(d), criminal penalties can reach a fine of up to $10,000 or up to one year in prison, plus civil liability for treble damages. Three times the amount of any charge paid. RESPA is enforced primarily by the CFPB, with state attorneys general and private lawsuits also available. The “thing of value” definition is broad enough to include even small gifts, which is why disclosure and keeping referrals separate from settlements matter.
Are realtor contractor referral fees legal under RESPA?
Realtors can refer contractors, but the RESPA risk concentrates when a fee is tied to or conditioned on a real-estate transaction or mortgage settlement. The cleanest realtor referrals are post-closing and decoupled from the deal. Because of this exposure, property managers, whose referrals are typically maintenance-driven and non-transactional, are the cleanest, highest-volume affiliate profile.
Can home inspectors accept contractor referral fees?
Generally no. InterNACHI’s Code of Ethics and various state rules prohibit home inspectors from accepting referral fees from contractors, because of the conflict of interest between flagging a problem and profiting from the repair. Home inspectors are effectively not a viable affiliate profile for paid contractor referrals.
What does Arizona law say about paying referral compensation to unlicensed people?
A.R.S. 32-2155(C) makes it unlawful to pay compensation for licensed real-estate broker acts to anyone not licensed at the time the service is rendered, and A.R.S. 32-2101 defines those broker acts (selling, leasing, managing real estate). A contractor home-services referral is not among those enumerated real-estate acts, so it falls outside that prohibition, while property managers should still keep referral income separate from their paid management duties.
How is a pay-on-completion referral different from buying leads on Angi or HomeAdvisor?
Pay-per-lead marketplaces charge contractors upfront for leads that are typically shared with several contractors at once, with shared-lead close rates under 10% and referral cost-per-lead averaging about $52 versus roughly $135 for HomeAdvisor and Angi (Siana Marketing). An exclusive, pay-on-completion model sends one Pro per job, never resold, and the success fee is owed only when the job completes.
How does an affiliate partner get paid in a referral marketplace?
The referrer sends in homeowner demand, a listed Pro does the work, and a fee is owed only when the job completes, never per lead. The referrer earns 50% of that fee. The fee itself is not a rate card: each company chooses at sign-up what a closed job is worth to them, and payouts are settled with you directly after the job closes.
How do I start earning contractor referral income the RESPA-safe way?
Confirm your profile is clean (property managers and well-connected locals are best), disclose the referral relationship in writing, keep referrals separate from any real-estate or mortgage transaction, refer through a registry that shows each Pro’s AZ ROC license number and sends one Pro per job, and collect a fee only when the job completes. Always treat referral income as separate from any licensed real-estate or management activity.