Transparency | Accountability | Separation of Interests

Welcome to the official Legal & Compliance Center for all entities. This page provides clear definitions, ownership structure, regulatory compliance protocols, and answers to any question about how we operate across multiple companies — with strict separation of duties, full RESPA/TILA/HUD compliance, and proactive auditing.

✅ 1. Corporate Structure & Entity Separation

Circle Consulting LLC

Type: Marketing & Technology Company

Function: Creator of the Circle Points™ system, Circle Marketplace™, and all agent/vendor engagement tools.

Ownership: Solely owned by Andrew Heisley

Not a settlement service provider under RESPA

Does NOT originate loans, handle closings, or accept mortgage applications

Circle Home Loans

Type: Mortgage Brand

Structure: DBA under Priority 1 Lending LLC

Function: Retail mortgage division offering residential loans in compliance with federal lending laws

Circle Points Issuer: Issues Circle Points ONLY after closed transactions and permissible engagements

Regulated by: NMLS, RESPA, TILA, FHA/HUD, CFPB

Ownership: Operates under Priority 1 Lending LLC, which is independently owned

Priority 1 Lending LLC

Type: Licensed Direct Lender (NMLS #)Function: Full-service residential mortgage lender operating in 36+ states

Affiliations: Circle Home Loans is one of many DBAs under its license umbrella

⚖️ 2. Regulatory Safeguards

RESPA Compliance: No referrals are incentivized. No payment for steering. All points and incentives are post-closing and tied to performance.

TILA & CFPB Disclosures: All consumer-facing materials include clear, truthful, and non-misleading disclosures.

HUD Guidelines: We follow all HUD statements including 1996-2 Joint Marketing interpretation.

Audit Trail: Full CRM-based tracking of every interaction, closing, point awarded, and dollar spent on marketing.

Co-Marketing Rules: All marketing spend is split proportionally or paid directly from Circle Consulting (non-lender).No Upfront Marketing: No deliverables before loans close. No exceptions.

🛡 3. Circle Points™ Program – Legal Overview

Circle Points™ is created by Circle Consulting and issued by Circle Home Loans after closed mortgage transactions. Points are not earned or usable unless a mortgage funds.

Not cash. Not transferable. Not commissions. Not paid in exchange for referrals.

For full legal breakdown, visit: [Circle Points™ Compliance PDF →]

📁 4. Common Legal FAQs

Q: Is Circle Consulting a mortgage company?

A: No. It is a marketing and software company. It does not offer loans, process applications, or handle closings.

Q: Do agents get paid for referrals?

A: No. Circle Home Loans does not pay for referrals. Points are awarded only after services are rendered and a mortgage funds.

Q: Can this be considered a kickback?

A: No. There is no agreement, expectation, or incentive for referral activity. The program is 100% post-close and performance-based.

Q: Is everything traceable?

A: Yes. Every activity is logged, archived, and independently reviewable by compliance staff and third-party auditors.

📜 5. Program Disclosures & Downloads

✅ Circle Points™ Terms & Conditions

✅ Circle Consulting Scope of Work

✅ Circle Home Loans Branch Guidelines

✅ Marketing Co-Investment Agreement Template

✅ RESPA Compliance White Paper

✅ Vendor Partnership Terms

✅ Agent Onboarding Compliance Guide

✅ NDA Template (for presentations)

👤 6. Who to Contact

Compliance Officer (Mortgage Licensing & Advertising)
Email: [email protected]

Legal & Marketing Structure Questions
Email: [email protected]

Public Inquiries or Subpoena Service
Email: [email protected]

🔍 Everything You Need. Nothing to Hide.

This page is regularly updated by our legal counsel and internal compliance team.

If you have questions, ask. We don’t operate in shadows.