Loan Officer Closing and Holiday Gifts for Borrowers, and Why the Gift Goes to the Borrower, Not the Agent

We sell a $35 logo mug gift box, printed, packed and shipped to each person's address. This guide covers the other options too.

Key facts

• Asked whether a lender can give a consumer a gift for using its services, the CFPB answers "Generally, yes" (CFPB RESPA FAQs, updated Oct 7, 2020).
• In its separate answer on gifts and promotions, the CFPB says: "There is no exception to RESPA Section 8 solely based on the value of the gift or promotion."
• USPS recommends sending Ground Advantage by Thursday, Dec 17, 2026 for Christmas delivery in the lower 48 (USPS).

This page is part of our client gifts by profession guide.

What do loan officers give borrowers at closing?

Loan officers ask each other this on r/loanoriginators: "What's the best and easiest closing gift you've given to your clients?" (2023).

A closing gift works when it is useful in the new home, comes from you as a person, and takes you minutes per borrower, not an afternoon. The buyer's agent may be giving a closing gift too, so yours doesn't need to be big. It needs to be yours.

Timing: a few weeks after closing beats closing day. One commenter on r/RealEstate put it this way: "Many agents don't give gifts at closing because there's too much going on. They wait a month and drop by with something, or they send a gift at the holidays" (r/RealEstate). A gift that lands after the moving boxes are unpacked is easier to notice. For the agent's side of the same moment, see closing gifts for buyers and sellers.

Why does the gift go to the borrower, not the agent?

The CFPB answers the two cases separately. Replies on r/loanoriginators put it plainly: "Anything of value in exchange for leads is prohibited," and "Save that money and get their client a gift when you close their loan" (r/loanoriginators). Here is the text behind that advice.

Reg X lists settlement services, among them "(4) Provision of title services," "(8) Rendering of inspections" and "(14) Rendering of services by a real estate agent or real estate broker" (12 CFR 1024.2(b)).

"No person shall give and no person shall accept any fee, kickback or other 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."

An agreement "need not be written or verbalized but may be established by a practice, pattern or course of conduct."

Reg X, 12 CFR 1024.14(b) and (e) (the CFPB's current version, read Oct 29, 2026)

"Are gifts and promotions allowed under RESPA Section 8?"

"It depends." … "There is no exception to RESPA Section 8 solely based on the value of the gift or promotion."

CFPB RESPA FAQs, Gifts and Promotional Activity (updated Oct 7, 2020; read Oct 29, 2026)

"What conditions does Regulation X establish for gifts and promotions to be 'normal promotional and educational activities' allowed under RESPA?"

… "If an item or activity is targeted narrowly towards prior, ongoing, or future referral sources, this could indicate the item or activity is conditioned on referrals of business."

CFPB RESPA FAQs, Gifts and Promotional Activity (updated Oct 7, 2020; read Oct 29, 2026)

For gifts to consumers, the CFPB has a separate FAQ:

"Under RESPA Section 8, can a lender or other settlement service provider give a gift, refund, or discount to a consumer for using that lender or provider?"

"Generally, yes." … "However, RESPA Section 8 prohibits, for example, giving an incentive to a consumer in exchange for the consumer referring other business to that lender or other settlement service provider." … "Other federal and state laws may also have restrictions that apply and should be consulted."

CFPB RESPA FAQs, RESPA Section 8 General (updated Oct 7, 2020; read Oct 29, 2026)

A real case: in 2023 the CFPB ordered Freedom Mortgage to pay a $1.75 million penalty. The things of value it gave for referrals included "free tickets to sporting events, charity galas, or other events" (consent order, ¶13; CFPB announcement, Aug 17, 2023).

What the text says, and doesn't: it gives no dollar amount below which a gift to a referral partner sits outside Section 8; the CFPB's word is "solely". Realtors face the same rule from their side (realtor client gifts). Full explainer: RESPA Section 8 in the CFPB's own words.

This is information, not legal or tax advice. Check the current rule (or ask your broker, counsel or compliance officer) before you send.

Can I co-brand a closing gift with the realtor?

Reg X: "Section 8 of RESPA permits: … (vi) Normal promotional and educational activities that are not conditioned on the referral of business and that do not involve the defraying of expenses that otherwise would be incurred by persons in a position to refer settlement services or business incident thereto"

12 CFR 1024.14(g)(1)(vi) (read Oct 29, 2026)

A gift you pay for that also carries the agent's name puts the second condition in play: does your money pay for marketing the agent would otherwise pay for? We found no CFPB answer specific to co-branded closing gifts. The nearest example in its gifts FAQ: paying for a referral source's "office supplies branded with the referral source's name, contact information, or logo" is "more likely to defray expenses of the referral source." Ask your compliance officer before you put two names on one gift.

This is information, not legal or tax advice. Check the current rule (or ask your broker, counsel or compliance officer) before you send.

Does the IRS $25 limit apply?

"You can deduct no more than $25 for business gifts you give directly or indirectly to each person during your tax year."

"Incidental costs, such as engraving on jewelry, or packaging, insuring, and mailing, are generally not included in determining the cost of a gift for purposes of the $25 limit. A cost is incidental only if it doesn't add substantial value to the gift. For example, the cost of gift wrapping is an incidental cost. However, the purchase of an ornamental basket for packaging fruit isn't an incidental cost if the value of the basket is substantial compared to the value of the fruit."

IRS Publication 463 (for use in preparing 2025 returns; read Oct 29, 2026)

Whether a gift box counts as incidental packaging depends on the facts; that judgment belongs to your tax professional. More in are client gifts tax deductible?

This is information, not legal or tax advice. Check the current rule (or ask your tax professional) before you send.

What should the card say to a borrower?

Two or three sentences about their home, not your rates. No referral ask. Your message is printed on the card (up to 300 characters). A closing gift is often an order of one box, so its message can be all theirs; a larger order prints one message, which can greet each borrower by first name. For example, signed "Chris":

• "Hi Ana and Ben, congratulations on the new house. It was a pleasure working with you on the loan. Enjoy your first cocoa in the new kitchen."
• "Hi Mark, a year in the new place already. Thank you for trusting me with your mortgage. Happy holidays!"
• "Hi {first name}, thank you for choosing me for your loan this year. Wishing you a warm first winter at home."

More lines: thank-you messages for clients.

What do loan officers send past borrowers for the holidays?

Your past-borrower list is your database. Past borrowers may buy again, refinance or move, and a holiday gift once a year is a thank-you that keeps your name in their kitchen. Keep it a thank-you for their own loan, with no strings.

USPS calls its dates "recommended," and actual delivery "may vary" (USPS).

How do I send a closing gift to each borrower?

1. Export your borrowers (name and mailing address) from your CRM or loan system into a spreadsheet. Start from our client address spreadsheet template.
2. Use the property address only once they've moved in. For past borrowers, confirm the current address; see how to ask clients for their address.
3. Send closing gifts in small batches a few weeks after funding, and holiday gifts once, by the order-by date above.

Can I pack and ship borrower gifts myself?

Yes: you can assemble and ship borrower gift boxes yourself, and by our estimate 25 logo mug gift boxes take about 9 hours of hands-on work (about 3½ of them packing, at about 8 minutes a box), plus a week or more waiting for supplies from about 8 separate orders. Per box, it comes out about even: about $38 with USPS counter postage and about $34 with commercial postage, with $1,192.84 paid up front for the mugs, the retail supply packs and 25 postage labels (our DIY cost comparison, prices as of Oct 29, 2026).

Closing gifts come one closing at a time, and each one means a box to pack and a trip to the counter. A mug packed without a foam collar can break at the handle and must be bought, packed and shipped again. With Personalized Gifts Delivered, one box is a complete order: you add the borrower, check the preview and pay. We print, pack and ship each box to its own address.

What to know before you order

• Your company's policy. Your company may have a gift policy of its own. The shipping spreadsheet lists each borrower's box at $35, for any approval or gift log it asks for.
• The treats. LINDOR truffles contain milk, soy and barley malt (gluten); read the labels.
• Where we ship. The lower 48 states and Washington, DC, except Texas for now; no Alaska, Hawaii, Puerto Rico, APO/FPO or international. The order page flags any row we can't ship to, so you can fix it or take it out.

Where Personalized Gifts Delivered fits for a loan officer's borrowers

A closing gift from you as a person, shipped to the new house:

• One borrower or a whole list. One box is a complete order, so a closing gift can go out the week you want it; a holiday list goes in one order, each box to its own address.
• A card about their home, printed with your message and greeting each borrower by first name. You see the mug and every card before you pay.
• No lender branding on the porch. Each box ships in a plain white carton; the return address shows PersonalizedGiftsDelivered.com, and your name appears only on the card inside. Your logo is printed small on the mug.
• A record for your compliance file. When your boxes ship, one email brings a spreadsheet of recipient, ship date, carrier, tracking number and $35 per box.

Add your logo (or type your website and we'll find it), or a photo or a few words for a personal gift; check the preview of your mug and card; add your address list; and pay $35 per box. We print, pack and ship each box to its own address. We ship from New York. Ships within 2 business days of a complete order (your design, your address list and payment). Ships by USPS Ground Advantage or UPS Ground, with tracking, and usually arrives 2–5 business days after it ships. Delivery dates are carrier estimates, not guarantees, and run slower in mid-December.

That way you can send a closing gift to each borrower: a custom logo mug gift box, shipped to each client, no minimum, with your name on the card and a mug for the new kitchen. Borrower list ready? Start your order: $35 per box, delivered.