“As a Broker in our Network, it is important to preserve and protect the relationship between the client and their chosen lender, Quicken Loans. The Broker agrees that he/she and his/her Partner Agents will educate themselves and the client on the benefits of using Quicken Loans and other Rock Family of Companies services. Purposefully steering a client from Quicken Loans to another mortgage lender is prohibited and could result in termination of the Broker’s relationship with Rocket Homes.”

💡 This language explicitly prohibited agents from steering clients to competitors and threatened termination for non-compliance.

“Partner Agent performance is a critical factor in assigning clients. Rocket Homes measures Partner Agent success within the client’s desired search area by monitoring the following Key Performance Indicators: . . . 2. Quicken Loans conversion . . . 4. Quicken Loans Mortgage Banker satisfaction rating.”

💡 Rocket Homes explicitly tracked how often agents successfully funneled clients to Rocket Mortgage and used this to allocate future referrals.

“Rocket Mortgage is the client’s chosen lender. Any purposeful steering away from Rocket Mortgage is prohibited. Also, Rocket Mortgage does not lend on manufactured homes or co-ops.”

💡 This warning appeared on every client profile and referral agreement, reminding agents they could not suggest alternatives.

“What’s great about the model I have established in our business is that I get the luxury of controlling and directing our agents to use the relationships I say we do. Which is why I am on a mission for Amrock and the exchange of business back to QL [reciprocal referrals].”

💡 Mitchell explicitly tied his request for additional referrals to the Mitchell Group giving Amrock and Rocket Mortgage Dog Bone referrals.

“The term ‘thing of value’ includes, without limitation, monies, things, discounts, salaries, fees [and] . . . the opportunity to participate in a money-making program.”

💡 The CFPB argues that Rocket Homes’ referrals themselves are things of value, making the quid pro quo arrangement illegal.

“Consumers who went through the Rocket Homes network and obtained a mortgage from Rocket Mortgage paid higher rates and fees than consumers who did not go through the referral network.”

💡 The complaint directly states that consumers who were steered to Rocket Mortgage paid more than those who were not.

“Rocket Homes punished a real estate agent for setting their client up with a local lender, who obtained $15,000 in down payment assistance from the Tennessee Housing Development Agency (THDA). Rocket Mortgage didn’t participate in the THDA program at the time.”

💡 Agents were penalized for helping clients access beneficial programs that could have saved them thousands of dollars.

“Mitchell taught his agents to create ‘a fear’ in their clients that they could lose the home they were trying to buy—and possibly their earnest money—if they considered any lender other than Rocket Mortgage.”

💡 Mitchell’s training materials explicitly encouraged agents to use scare tactics to prevent comparison shopping.

“Rocket Homes repeatedly pressured real estate brokerages to hit a capture rate of 80%. This meant that, of the Rocket Homes consumers who were referred to a real estate brokerage and ended up buying a home, Rocket Homes wanted at least 80% of those consumers to get their mortgage from Rocket Mortgage.”

💡 Rocket Homes set explicit numerical targets for how many clients should be funneled to Rocket Mortgage, showing the systematic nature of the scheme.

“Approximately 70% of Rocket Homes consumers are first-time homebuyers. And many state and local governments offer down payment assistance or other benefits to first-time homebuyers. But until August 2022, Rocket Mortgage had a blanket policy of not participating in any of those programs.”

💡 The most vulnerable buyers, those who would benefit most from assistance programs, were systematically denied access to information about those programs.

“An estimated 50% of all the penalties Rocket Homes assessed on real estate agents were for the agents’ violations of the preserve and protect requirement.”

💡 Half of all agent penalties were for trying to help their clients explore alternatives, showing how aggressively Rocket Homes enforced the scheme.

“Amrock is the Preferred Provider to Rocket Homes and Rocket Mortgage.”

💡 Rocket Homes explicitly told agents in mandatory training that Amrock was the preferred title company, encouraging referrals to yet another Rocket affiliate.

“An agreement or understanding for the referral of business incident to or part of a settlement service need not be written or verbalized but may be established by a practice, pattern or course of conduct.”

💡 The complaint relies on this regulatory language to show that even without a written contract, the repeated behavior established an illegal agreement.

“But when real estate agents accept things of value in exchange for referring their clients to a provider of other services, it corrupts the real estate agents’ relationship with their clients and taints their advice.”

💡 The CFPB describes exactly what the alleged scheme did: corrupted the agent-client relationship by making the agent’s advice conditional on receiving referrals.

“Real estate agents should make referrals and recommendations to their clients based on their professional judgment and in sole consideration of their clients’ best interests.”

💡 The complaint contrasts the legal and ethical duty agents owe their clients with the actual behavior Rocket Homes required.