This is a very legally grey area depending on who's in charge of the CFPB and who they're enforcing against. The short answer, in our opinion (although we're not attorneys and you should consult one if you're concerned) is it can be when done correctly. To the best of our understanding, co-marketing is done correctly when the access to the leads and costs are shared in direct proportion to the amount each party is being advertised. So if the lead is inquiring about homes for sale and the lender never works those leads, just expects every referral from the campaign to come through them, that would be non-compliant. But if an agent shares a landing page with a loan officer 50/50, and they split the cost of the advertisements 50/50, and they share responsibility for working the leads, it can be considered compliant.