Compare Neighborhoods.com and Tomo

For Sellers

Partner Agents
25%-40%
Referral Fee
Neighborhoods.com does not provide real estate services to home sellers. Instead, this company colludes with various listing agents in exchange for an undisclosed referral fee. Neighborhoods.com takes between 25% to 40% kickback from the net commission earned by the colluding Realtor. Collusion between any real estate entities is a felony.

For Sellers

Not Applicable
0
No Rates
Tomo Brokerage does not currently allocate home sellers to listing real estate agents.

For Buyers

Partner Agents
25%-40%
Referral Fee
Neighborhoods.com does not provide real estate services to home buyers. Instead, this company colludes with various buyer agents in exchange for an undisclosed referral fee. Neighborhoods.com takes a 25% to 40% kickback from the net commission earned by the colluding Realtor. Collusion between any real estate entities is a felony.

For Buyers

Partner Agents
25%-35%
Referral Fee
'Tomo Brokerage is a paper broker that does not provide real estate services to home buyers. Instead, this company allocates consumers to real estate agents in exchange for a hidden referral fee, likely set at 25%-35% of their entire commission. Tomo, via Tomo Mortgage, LLC mortgage brokerage further price fixes buyer commission rebates by converting commission kickbacks into discounted interest rates by offering a “perk” of 0.125% against the quoted interest rate in an effort to entice more consumers into the price fixing scheme with Tomo Brokerage
Question: What is the difference between Neighborhoods.com and Tomo?
Answer: Both Neighborhoods.com and Tomo function as a referral fee network that enables broker-to-broker collusion with use of blanket referral agreements.
Compare Neighborhoods.com and Tomo for home buying and selling. Geodoma is an impartial and an open resource focused on trending real estate services, portals and start-ups.

First published: 05 December 2024
Last updated: 05 December 2024

Buying and Selling with Neighborhoods.com

WARNING: Unlawful Kickbacks, Broker-to-Broker Collusion, False Marketing, Wire Fraud, Price Fixing.

Neighborhoods.com) is a broker-to-broker collusion scheme, where "partner agents" unlawfully agree to pay massive kickbacks to receive your information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices in violation of, inter alia, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, 12 C.F.R. § 1024.14. As a consumer, you will always significantly overpay for Realtor commissions subject to hidden kickbacks and pay-to-play steering promoted in this scheme.

United States federal antitrust laws prohibit consumer allocation and blanket referral agreements between real estate companies.

Be smart; do not allow your information to be "sold as a lead" to a double-dealing Realtor in exchange for massive commission kickbacks paid from your future home sale, or your future home purchase.


Neighborhoods.com is a broker-to-broker collusion scheme that allocates home buyers and home sellers to colluding Realtors through a "shell" real estate entity. When consumers submit information on the Neighborhoods.com website, this information is sold in exchange for an undisclosed fee with real estate agents in a process known as a pay-to-play steering and a "blind match." Neighborhoods.com, LLC is a "shell" real estate broker in Illinois that unlawfully allocates consumers with various uncompetitive and unethical Realtors.

Neighborhoods.com Pricing

Neighborhoods.com fees come from hidden kickbacks, likely set between 25% and 40% of the gross commission received by anyone in the network of colluding Realtors.

Listing Services

  • This Service Does Not Represent Sellers

Buyer's Agent Services

  • This Service Does Not Represent Buyers

Neighborhoods.com Editor's Review:

Neighborhoods.com, LLC (dba Neighborhoods.com) is a licensed real estate firm License No 481.012453 in the State of Illinois (55places is a licensed real estate firm License No 477.013455) operates as a "shell" broker to collect an undisclosed referral fee, likely set between 25% and 40% from the gross commissions, paid by all colluding Realtors in the network. This fee is inevitably passed down to consumers in a form of inflated real estate commissions when selling or buying any home.

More importantly, Neighborhoods.com is an active licensed real estate entity that does not engage in actual real estate broker services. Neighborhoods.com systematically applies pay-to-play bias towards all Realtor matching results, meaning, only Realtors that have agreed to collude and pay a referral fee are matched with consumers.

Neighborhoods.com, LLC claims that its "specialized online real estate marketplaces make a difference in the way people buy and sell their home." In the real world, Neighborhoods.com, LLC is a "shell" "sham" "paper" Illinois real estate broker that operates a nationwide broker-to-broker collusion scheme via https://www.55places.com/ and https://www.neighborhoods.com/ online web services. Neighborhoods.com falsely claims that "our real estate experts specialize in the purchase or sale of homes." In reality, this shell brokerage does not represent consumers when buying or selling a home anywhere, the "shell" brokerage scheme allocates consumers to random "partner agents" around the United States.

According to Neighborhoods.com website, "a Partner Agent is an agent that works for a brokerage that is not Neighborhoods.com or its affiliated brokerages (including Neighborhoods.com Connecticut Brokerage, LLC, Neighborhoods.com, LLC of Delaware, Neighborhoods.com Florida Brokerage, LLC, Neighborhoods.com Indiana Brokerage, LLC, Neighborhoods.com Nevada Brokerage, LLC, Neighborhoods.com Virginia Brokerage, LLC, Neighborhoods.com Minnesota Brokerage, LLC, or Neighborhoods Home Source, Inc.), but that partners with us to provide the Services."

Neighborhoods.com promotes its scheme to colluding Realtors where "the neighborhoods.com Partner Agent Program will not cost you anything unless we can put qualified prospects in your hands that result in a transaction for you." Neighborhoods.com further falsely claims to consumers that "the Company does not charge fees to use the Services."

In reality, real estate brokers never work for free. Neighborhoods.com operates through a hub-and-spoke conspiracy and consumer allocation scheme with a massive network of colluding competitors willing to secretly and unlawfully agree to give up a significant portion of their future commissions into the collusion scheme. Neighborhoods.com fees are exigent and are merely hidden in the price of commissions, eventually paid by consumers.

The colluding Partner Agents simply increase the price of their commissions to make up for the hidden kickbacks. Each broker in the collusion scheme knows that their services are promoted as a group ahead of others outside the scheme, therefore, benefitting from the lack of open competition. The scheme further requires colluding brokers to feed potentially private and confidential client information back to the broker-to-broker collusion "hub" where every Parter Agent is "expected to log all correspondence in the 55places.com Agent Portal." Such schemes are highly poisonous to healthy real estate representation markets because they operate through removing competitive forces between "spokes" and allocate consumers in scale through interstate commerce.

Realtors only sign-up with Neighborhoods.com because the price of the referral fee can be easily incorporated into their client's agreement with excessive commissions.

Neighborhoods.com receives a low Editor's rating because this service is a biased hub-and-spoke broker-to-broker collusion scam, that falsely claims to provide an independent and unbiased service of matching consumers with agents. Neighborhoods.com is not a marketplace, but a licensed "sham" real estate brokerage.

Neighborhoods.com operates on a pay-to-play methodology to collect junk fees that needlessly make home buying and selling more expensive. In this scheme, consumers are no longer in the driver's seat, but instead, are traded as a commodity between licensed brokers.

Neighborhoods.com plays junk fees down, claiming that the service is "free" "unbiased" and "no obligation" to consumers, but it rigidly locks every participating Realtor into a kickback attached to the back-end of every agreement that restrains free trade. As a licensed real estate entity that doesn’t perform any real estate services or take any responsibility for the transaction, this scheme operates to unlawfully allocate consumers and bypass RESPA anti-kickback regulations through a "shell" entity. Neighborhoods.com scam operates on a false notion that all buyer agent and listing agents commissions are the same, where no colluding Realtor in the Neighborhoods.com scheme competes for consumers on pricing.

Consumer brokering is an act of selling information of potential home buyers and home sellers (paid referrals) between real estate brokers, in exchange for a cut of a broker’s commission. Brokers on each side of the adopted scheme, cause direct damage to the real estate representation market with reverse competition, anticompetitive market allocation, price-fixing, lack of competition, limited choices to consumers, unnecessary high commissions, and improperly negotiated fees. A referring broker in this scheme does not compete with referred brokers, instead, Neighborhoods.com administers a series of agreements that restrain free trade, disguised as Realtor matching services.

12 C.F.R. § 1024.14(g)(1)(v) (Regulation X) and RESPA 12 U.S.C. § 2607(c)(3) narrowly allow payments pursuant to cooperative brokerage and referral arrangements between real estate agents and real estate brokers. This limited exemption on kickbacks only applies to fee divisions within real estate brokerage arrangements when all parties are acting in a real estate brokerage capacity. Neighborhoods.com shell entity does not act in a brokerage capacity, in fact, this entity willfully chooses to disengage from offering real estate representation services to consumers, as the core premise to create successful collusion through interstate wire communication to further the scheme. Wire fraud is financial fraud involving the use of any telecommunications or information technology.

Real estate transaction is a rare, high-value, and high-risk-aversion experience that is easily subjected to unlawful kickbacks, especially with the use of the Internet. Consumers are often subjected to high commissions and hidden referral fees without a full understanding that these fees increase their commissions and result in a lower quality of service. Whenever any double-dealing Realtor agrees to pay these massive kickbacks, he or she is unable to offer full and competitive representation services to anyone. Neighborhoods.com does not cater to honest Realtors, it only caters to Realtors willing to cheat their clients out of full services, and willing to share private information about their clients' transactions with the scheme.

Neighborhoods.com antitrust and consumer protection violations are not harmless. Realtors who attempt to compete for consumers on fair terms and competitive pricing are at a massive disadvantage in this environment. As a result of broker-to-broker collusion, consumers end up getting steered toward a limited pool of dishonest Realtors and overpay for commissions. Consumers’ private transaction information is always shared with a referring broker that requires it to be disclosed to calculate the referral fees to be paid at the close of each transaction.

Consumers, of course, pay for this abuse with higher costs of commissions that, eventually, make it directly into their new mortgages and cause significant losses of net equity from a home sale.

A typical broker-to-broker collusion scheme often attempts to fool consumers with heavily advertised campaigns on Google, Nextdoor, Facebook, or local radio and TV. Such a false ad might read: "Unbiased. Get Data-Driven Results. Our Agents Can Get You the Best Deals. Sign Up Now! Save Time & Hassle and Get Matched to the Perfect Agent for Your Needs. Find Quality Realtors. Top Agent Rankings. Personalized & Fast. 100% Free. Top 1% of Real Estate Agents Compete to Sell Your Home. No Obligation. Save Thousands."

In reality, all such "matches" are 100% biased, pay-to-play collusion steering mechanisms between licensed brokers, and they all cost consumers tens of thousands compared to open market savings. These "paper" brokers do not connect consumers with anyone outside the network, in fact, they specifically steer consumers into the network in exchange for massive kickbacks pre-negotiated in advance.

There are numerous reasons why consumers are wise to avoid the Neighborhoods.com scheme, but probably the most important reason is that the lack of transparency and honesty is contagious. Neighborhoods.com scheme attracts ONLY double-dealing Realtors who are willing to break a host of federal antitrust laws, and unwilling to compete for consumers with transparency. An unethical Realtor will always find a way to turn the most important transaction into a self-dealing proposition - to collect a bigger commission check faster without any regard for what is truly a good deal for their clients.

Why Does Neighborhoods.com Engage in Collusion?

Plain agreements among competitors to divide sales territories or assign customers are almost always illegal. These arrangements are essentially agreements not to compete.

Neighborhoods.com engages in consumer allocation because it is an active real estate entity that refuses to compete with other real estate agents who patriciate in the scheme. This dynamic is better known as a hub-and-spoke conspiracy. In a hub-and-spoke type conspiracy, all Realtor commissions are set at the same amount for all Realtors, where none of the "partner agents" compete with one another on pricing at all. Neighborhoods.com scheme produces absolutely no tangible service as a licensed broker to anyone and instead delivers inflated prices and lower quality of service. The scheme originates as a conspiracy to restrain trade and to funnel consumers toward the scheme and away from the open market. There are hundreds of thousands of highly competitive Realtors who offer great savings and great service, and they refuse to pay kickbacks or collude with Neighborhoods.com shell brokerage.

The illicit kickback is the reason why Neighborhoods.com colludes with Realtors outside their firm. This is also the reason why the scheme does not mention this kickback anywhere on their website. ALL consumers and ALL legitimate Realtors are scammed by Neighborhoods.com, even if the experience may seem "good enough" because collusion is a faulty shortcut to genuine open competition between Realtors. Federal laws require all Realtors to compete for consumers and to deliver a tangible service, a simple test Neighborhoods.com, LLC entity decisively fails. Open competition is at the core of our free and independent society everywhere in America.

The Realtor commissions in the United States have long suffered from the "standard" 6% myth and the false notion that "buyer agents work for free." Neighborhoods.com is a direct extension of these uncompetitive, unethical, and unlawful notions. ALL Realtors who participate in the Neighborhoods.com scheme are engaged in plain collusion, where each Realtor knows that Neighborhoods.com, LLC shell brokerage will not compete at all, in exchange for a blanket kickback from the home sale or a home purchase. The Sherman Act imposes criminal penalties of up to $100 million for a corporation and $1 million for an individual, along with up to 10 years in prison for each count. Persons found guilty of wire fraud under federal law face fines up to $250,000 for individuals and up to $500,000 for organizations, subject to imprisonment of not more than 20 years. There are additional penalties of 30 years imprisonment and a million-dollar fine if the wire fraud involves a financial institution. These penalties are per count, which means that each electronic communication can be considered as a separate count. No legitimate Realtor will ever willingly allow themselves to be exposed to such massive liability.

The best, highly-experienced, well-educated, law-abiding, honest, and ethical Realtors will never participate in collusion because it is a felony that carries massive penalties. The best Realtors can recognize collusion as wrong because they respect the true value of honest negotiations.

When Neighborhoods.com refuses to compete with these brokers and instead organizes "partner agents" into a network, it breaks an entire host of basic open commerce principles that guide our open and fair markets. Moreover, Neighborhoods.com extends this conspiracy all across the United States via its website, making the scheme highly damaging due to the scaled use of the Internet to transmit collusion. The Internet, like any other scaled telecommunications medium, can be used to transmit open competition just as easily as pay-to-play fraud.

Most consumers do not know that Neighborhoods.com, LLC is a licensed real estate brokerage that collects a massive kickback from their transactions because the nature of the scam requires this information to be deliberately hidden. Neighborhoods.com scam is built entirely on false advertising to deliberately deceive consumers. This shell broker presents itself as an unbiased marketplace, but it is a real estate broker that engages in unlawful activities under federal laws. The short answer is: Neighborhoods.com's intent to allocate consumers as a secret real estate shell entity is directly tied into the kickbacks it receives from the "partner agents." This dynamic is a product of the restraint of genuine competition. The "standard commissions" problem in the residential real estate sector can only be fixed legally by encouraging Realtors to set and advertise competitive prices to consumers at scale without paying any kickbacks.

Where does Neighborhoods.com operate?

Neighborhoods.com currently operates in select areas across United States.

Buying with Tomo Brokerage

WARNING: Unlawful Kickbacks, Broker-to-Broker Collusion, False Marketing, Wire Fraud, Price Fixing.

Tomo) is a broker-to-broker collusion scheme, where "partner agents" unlawfully agree to pay massive kickbacks to receive your information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices in violation of, inter alia, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, 12 C.F.R. § 1024.14. As a consumer, you will always significantly overpay for Realtor commissions subject to hidden kickbacks and pay-to-play steering promoted in this scheme.

United States federal antitrust laws prohibit consumer allocation and blanket referral agreements between real estate companies.

Be smart; do not allow your information to be "sold as a lead" to a double-dealing Realtor in exchange for massive commission kickbacks paid from your future home sale, or your future home purchase.


Tomo Brokerage is a paper brokerage that operates a consumer allocation and a price fixing scheme designed to collect hidden referral fees by matching consumers with local real estate agents willing to pay it. Tomo Brokerage operates under a Texas TREC License #9010749 issued to Tomo Brokerage, Inc., but it does not produce any services that are typically offered by real estate agents and does not represent consumers when buying or selling real estate in any State.

In exchange for matching consumers with an Tomo Brokerage Partner Agent, Tomo Brokerage is compensated by the Partner Agent with a hidden kickback, likely 25%-35% cut of their commission. The company partnered with real estate coach Tom Ferry to build out their collusion scheme with a network of independent agents across multiple states.

Tomo Brokerage Pricing

Tomo Brokerage revenue comes from the use of blanket referral agreements with random real estate brokers. Tomo Brokerage is a broker-to-broker collusion scheme that scrubs consumers' information from their mortgage operations and passes it along to a colluding broker who is willing to pay for it with a cut of their commission. Tomo Brokerage’s blanket referral agreements effectively operate on a longstanding myth that buyer agents work for free. In reality, a homebuyer can negotiate a sizable commission refund with a competitive buyer agent in 40 US states from the Buyer’s Agent Commission (typically offered at 2.5%-3% BAC) received.

Tomo Brokerage, in effect, operates as a price-fixing scheme that converts a small portion of the kickback they receive into "perks." Tomo dangles these "perks" as carrots in front of consumers, currently fixed at an interest rate set discount at 0.125% if customers use a Tomo Brokerage Partner Agent. These “perks” savings, in reality, are dismal, compared to thousands in kickbacks received by Tomo for the act of pay-to-play steering. In this scheme, consumers end up giving up an opportunity to receive massive amounts of cash rebates (thousands or tens of thousands depending on the overall home price) available to them in the open market from highly competitive agents who offer in legitimate tax-free buyer’s cash refunds to compete for homebuyers’ business.

Listing Services

  • This Service Does Not Represent Sellers

Buyer's Agent Services

  • This Service Does Not Represent Buyers

Tomo Editor's Review:

Tomo claims to be a different consumer-focused company, but in reality, it is in of the worst VC-backed real estate pay-to-play consumer steering schemes. For consumers, Tomo Brokerage promises a real estate agent “concierge” platform for top local real estate agents. By gathering consumers’ home preferences and budgets while shopping for a mortgage with Tomo Mortgage, Tomo Brokerage scrubs users’ information and feeds it into their limited pay-to-play network of real estate brokers. According to Tomo's website Privacy Policy, they sell consumers’ information to any number of other services. This pay-to-play dynamic is unlikely to represent the consumer’s best options. Whoever pays Tomo some form of kickbacks, in effect, is who they pass consumers’ information to:

“In some circumstances, we share your information with third parties not owned by or co-branded with Tomo Mortgage that benefit directly from our sharing your information with them.”

Tomo Mortgage may even sell consumers’ information to competing lenders:

“Third-party lenders. If Tomo Mortgage cannot finance your home, we may share your personal information with one of our partner lenders.”

Tomo further may attempt to sell consumers’ information to random home insurance companies:

“Home insurance agencies. If your real estate transaction is such that you may need homeowners insurance, we may share your information with homeowners insurance agencies and those agencies may reach out to you directly to offer you a quote.”

For real estate professionals, Tomo Brokerage promises a “no upfront costs” lead generation by scrubbing consumers’ information when they shop for their mortgage. Once a potential homebuyer is identified, a Tomo Brokerage initiates a transfer to the Partner Agent. Tomo Brokerage representatives give Partner Agents all the background information on the homebuyer to make the transition.

In other words, Tomo Brokerage is a consumer allocation scheme between licensed real estate brokers that scrubs consumer’s information and passes it along to a broker who is willing to pay for it with a cut of their commission. If a broker is unwilling to give a portion of their commission to Tomo Brokerage, the company has no interest in recommending them. Tomo Brokerage further takes no responsibility for any of the actions of the brokers that they allocate to consumers.

In effect, Tomo Brokerage is a self-serving scheme designed to funnel consumers toward brokers who pay them a hidden kickback at the close of consumers’ transactions. Consumers using Tomo Brokerage have zero control over what agents the company shares their information with. Instead of being scrubbed and sold as leads, consumers looking for a competitive and fair representation can consider negotiating directly with real estate agents, or with help from unbiased consumer-focused online services that do not collect kickbacks.

Tomo attempts to present this pay-to-play scheme differently:

"Tomo Brokerage only works with Partner Agents that meet its high standards of customer-centric service, and they have to be experts in the areas you want to live in. They help you hone in your search criteria, find great homes, negotiate a great deal, and navigate the entire process. They can also help you identify qualified professionals to put the finishing touches on your new home."

These claims are entirely false. Tomo Brokerage only works with brokers who pay them kickbacks. These agents engage in consumer allocation with Tomo Brokerage. The act of consumer allocation between licensed brokers is a prohibited practice in the United States, by the virtue of the Sherman Antitrust Act. Tomo Brokerage Partner Agents are unlikely to have consumers' best interests, and, because they have to pay a kickback, they do not earn their full commissions. In effect, these agents work for consumers half the time, and for Tomo, the other half.

Even considering the overall dishonesty, kickbacks, and legal implications of the scheme, a consumer can technically still use Tomo Mortgage and freely negotiate a competitive buyer refund elsewhere on the open market with any agent.

There are honest and competitive buyer agents who are willing to share a cut of their commissions with consumers, as a legitimate way to earn business, rather than paying hidden kickbacks to Tomo Brokerage. Tomo Mortgage does not require consumers to use Tomo Brokerage, but it instead dangles an interest rate discount (set at 0.125%) so that homebuyers think that there are savings available to them. Tomo Brokerage's hidden kickbacks cost consumers thousands in properly negotiated fees while funneling hidden fees back into the scheme itself. These hidden kickbacks, eventually, reside in consumers’ mortgages and collect interest.

Price Fixing with Tomo Perks

Broker compensation fees must never be fixed via agreements between two or more brokers anywhere in the United States. All commissions and rebates must be set by each real estate agent individually and may only be negotiable between the consumer and the real estate agent. Buyer agents never work for free.

Genuine quality and honest real estate professionals establish pricing for their services independently, and without any kickbacks. The truth is, every single agent is different, and every single agent has an individual commission structure. If an agent is unwilling to negotiate competitive buyer rebate terms in compliance with the law, there is no reason for homebuyers to assume that they will be willing to negotiate competitively when it comes to their home purchase.

In combination, Tomo Mortgage and Tomo Brokerage terms equate to price fixing rates of independent real estate professionals who do not work for either one of these entities. Price fixing between independent business entities is a felony everywhere in the United States.

Tomo Perks Terms and Conditions

Subject to the following terms and conditions, customers who buy a home with Tomo Mortgage and a Tomo Brokerage Partner Agent qualify for Tomo Perks, which lowers their mortgage interest rate by 0.125%:

Tomo Brokerage Partner Agent. The customer must be party to a fully executed home purchase contract that identifies a Tomo Brokerage Partner Agent as their real estate agent, and Tomo Brokerage must have a record of referring the customer to the Partner Agent.

Tomo. The customer must purchase the home referenced above using a mortgage loan from Tomo with a loan amount of at least $150,000.

Rate Lock. The Tomo Perks interest rate reduction will be applied when the customer locks in their interest rate.

Modification. Tomo may modify the terms of Tomo Perks, but when it does so they will be modified only for customers who entered into purchase contracts after the date the program terms were modified.

Consumer Allocation

Tomo Brokerage is a broker-to-broker collusion scheme. All Partner Agents agree to pay Tomo Brokerage a pre-arranged referral fee, on all closed transactions, through their employing broker. A referral agreement between Tomo Brokerage and a Partner Agent for a random transaction that may or may not happen sometime in the future is executed in advance.

Tomo Brokerage engages in consumer and market allocation agreements with Partner Agents brokerages, because it is a broker itself. Instead of representing consumers to help buy and sell homes, this “paper” brokerage actively disengages from its licensed activities so that every Partner Agent knows that Tomo Brokerage, Inc. will not compete with them. Tomo Brokerage does not act in a real estate brokerage capacity, instead, their real estate license is used to collect a blanket referral fee from the largest number of brokers possible.

Sherman Antitrust Act effectively requires all active real estate brokers to proactively compete for consumers. An agreement or an understanding between brokers not to compete for a mutual benefit is a "per se" violation of antitrust regulations in the United States.

The amount of a referral fee between brokers must be negotiated with respect to an individual transaction. It is a per se violation of the Sherman Antitrust Act for real estate brokers to agree on a “standard” referral fee that will be paid for producing a client. Real estate professionals are not allowed to enter into blanket referral agreements between one another because such agreements always restrict free trade.

Brokers are not allowed to organize their operations into any collusion schemes and networks, and instead, all brokers must compete for consumers on a fair playing field. Legitimate agents who choose NOT to engage in the Tomo Brokerage “no upfront costs” scheme are harmed as well because consumers are steered away from them in a highly competitive real estate market.

Kickbacks and Unearned Fees

RESPA, among other things, is designed to prohibit abusive practices such as kickbacks and referral fees between mortgage companies and real estate brokers.

The statutory exemption for a payment to a cooperative brokerage and referral arrangements between real estate agents and real estate brokers requires all agents to compete against one another. To comply in good faith with RESPA (12 U.S.C. 2607) Section 8 exception for cooperative brokerage and referral arrangements, legitimate real estate agents must render referral agreements in a particular instance for a particular transaction.

Actions of Tomo Brokerage “paper” brokerage directly increase the costs of owning homes in the United States due to added blanket referral fees, consumer allocation practices, price fixing, and reverse completion between brokers. Partner Agents in the scheme have no incentive to compete for consumers individually with lower fees, instead, they have an incentive to compete for Tomo Brokerage’ attention. In this scheme, both colluding parties benefit from offering consumers higher commissions. Tomo Brokerage promotes Partner Agents as somehow “superior” to those outside of the network, thus limiting free-market competitive forces and steering consumers in self-interest toward a network of very few agents who chose to agree to participate in the scheme.

Similar attempts to by-pass RESPA prohibition against kickbacks by means operating a paper brokerage in a combination with services of a mortgage broker are not new. Similar schemes include:
Blend and Blend Brokerage
Better.com and Better Real Estate
HomeStory and a number of third-party lenders
Rocket Mortgage and Rocket Homes
loanDepot and mellohome
Nationstar Mortgage (dba Mr. Cooper) and Xome
and possibly some others. CFPB is currently investigating at least one of these schemes, Rocket Homes, and consumers must exercise great care to protect themselves in the meantime. A real estate home purchase is one of the most important transactions and it must be free from hidden kickbacks and self-steering.

In the real world, Tomo Mortgage and Tomo Brokerage are a single company, both designed and built with massive VC capital to rake hidden fees, by-pass RESPA, collude with independent brokers for a cut of their commissions, and openly price-fix services of others.

The entire RESPA prohibition against kickbacks was enacted specifically to stop mortgage companies from entering into “symbiotic relationships” with real estate brokers. Tomo Brokerage may seem like a clever by-pass of RESPA’s prohibition against kickbacks, but this loophole is built entirely on the use of blanket referral agreements between brokers designed to restrain free trade.

As an active licensed brokerage, Tomo Brokerage owes absolutely no duty of care to consumers, takes no responsibility for the transaction, and does not help consumers to buy homes - all despite receiving a direct financial benefit from the home purchase completed by the homebuyer.

Where does Tomo operate?

Tomo currently operates in select areas across Dallas-Fort Worth, TX, Houston, TX, Seattle, WA.