# Title and Escrow Gift Rules, Quoted: Washington's $5, California's $10 and Florida's $25 Figures, Plus RESPA

Three state title rules put dollar figures on gifts: Washington's on logo items to a producer, "five dollars or less"; California's on logo items, "not more than ten dollars ($10) each"; Florida's on merchandise, "not more than $25". The CFPB adds that RESPA has "no exception … solely based on the value of the gift or promotion."

*We sell a $35 logo mug gift box, printed, packed and shipped to each person's address. This page quotes the title rules and RESPA and does not tell you what you may give.*

**Key facts** (each text re-read October 29, 2026):

- **Washington:** logo items "except money or gift cards, to a producer if the cost to the title company is five dollars or less per thing of value" ([WAC 284-29-225](https://app.leg.wa.gov/WAC/default.aspx?cite=284-29-225)).
- **California:** logo promotional items "with a value of not more than ten dollars ($10) each"; "Expenditures for food, beverages, and entertainment for a person" are "per se inducements" ([Ins. Code §12404](https://california.public.law/codes/insurance_code_section_12404)).
- **Florida:** "for the purpose of advertising, any article of merchandise having a value of not more than $25" ([Fla. Stat. §626.9541(1)(m)2](http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0626/Sections/0626.9541.html)).
- **RESPA:** "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" for referrals ([12 CFR 1024.14(b)](https://www.ecfr.gov/current/title-12/section-1024.14)).
- **Consumers:** asked about a gift to a consumer "for using that lender or provider", the CFPB answers "Generally, yes" ([CFPB RESPA FAQs](https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/real-estate-settlement-procedures-act/real-estate-settlement-procedures-act-faqs/)).

More trades in [client gifts by profession](https://personalizedgiftsdelivered.com/professions); every limit in one table on [client gift limits by industry](https://personalizedgiftsdelivered.com/gift-rules/client-gift-limits-by-industry).

## Washington $5, California $10, Florida $25: The Three Title Rules We Read

Each state's words for the figure, the recipient and the exclusions:

| State | The figure in the text | The text's words for the recipient | Conditions and exclusions in the text | Source |
|---|---|---|---|---|
| Washington | "five dollars or less per thing of value" | "a producer" | "money or gift cards"; any item with "the name or logo of the producer" | WAC 284-29-225 |
| California | "not more than ten dollars ($10) each" | None in the $10 clause; (c)(8): "a person" | "a gift certificate, gift card, or other item that has a specific monetary value on its face"; food, beverages and entertainment are "per se inducements" | Ins. Code §12404 |
| Florida | "not more than $25" | "insureds, prospective insureds, or others" | Given "for the purpose of advertising" | Fla. Stat. §626.9541(1)(m)2 |

### Washington: "five dollars or less," with the title company's logo only

> "A title company may give a thing of value with its preprinted company logo, except money or gift cards, to a producer if the cost to the title company is five dollars or less per thing of value and only if the thing of value does not contain the name or logo of the producer or any reference to the producer."
>
> [WAC 284-29-225](https://app.leg.wa.gov/WAC/default.aspx?cite=284-29-225), "Self-promotional items" (effective March 20, 2009). Read October 29, 2026.

The chapter's scope section quotes the statute behind it, RCW 48.29.210(2): a title insurer or agent "shall not, directly or indirectly, give anything of value to any person in a position to refer or influence the referral of title insurance business to either the title insurance company or title insurance agent, or both, except as permitted under rules adopted by the commissioner." It adds: "If the thing of value is not clearly and specifically included in WAC 284-29-200 through 284-29-265 as a thing of value that a title company may give to a person, its giving is prohibited" ([WAC 284-29-200](https://app.leg.wa.gov/WAC/default.aspx?cite=284-29-200)). The definition of "producer" in WAC 284-29-205(9) "includes associates of producers and any person in a position to refer or influence the referral of title business to the title company."

The chapter's list of things a title company must not give a producer includes gift cards (WAC 284-29-260(6)(p)), and "A title company must keep and maintain complete, accurate, and sufficient records to demonstrate compliance" for "five years after the end of the year during which any thing of value was given to a producer" (WAC 284-29-265(1)).

### California: "ten dollars ($10) each," and food is a "per se" inducement

> "(c) The following activities, whether performed directly or indirectly, are deemed per se inducements for the placement or referral of title insurance business by any person and are unlawful: … (8) Expenditures for food, beverages, and entertainment for a person."
>
> "(d) Expenditures for the following are not deemed to be unlawful or in violation of this section: (1) Promotional items with a permanently affixed company logo of the underwritten title company, title insurer, or controlled escrow company, with a value of not more than ten dollars ($10) each. "Promotional item" does not include a gift certificate, gift card, or other item that has a specific monetary value on its face, or that may be exchanged for any other item having a specific monetary value."
>
> "(3) Other expenditures for a person, as permitted by the Department of Insurance by regulation."
>
> [Cal. Ins. Code §12404](https://california.public.law/codes/insurance_code_section_12404) (California.Public.Law, which checked the official text on October 26, 2026; the state's own site refuses automated reads). Read October 29, 2026.

The same section defines "Person" as "any individual or entity who is any owner or prospective owner, lessee or prospective lessee of real property or any interest therein" … "or any person who is acting or who is in the business of acting as agent, representative, attorney, or employee of those persons" (§12404(b)(2)). Subsection (e) adds that consideration "not specifically set forth in this section shall not be presumed lawful merely because they are not specifically prohibited." We have not read the Department of Insurance's regulations under (d)(3).

### Florida: "not more than $25," for the purpose of advertising

> "2. The provisions of paragraph (f), paragraph (g), or paragraph (h) do not prohibit a title insurance agent or title insurance agency, as those terms are defined in s. 626.841, or a title insurer, as defined in s. 627.7711, from giving to insureds, prospective insureds, or others, for the purpose of advertising, any article of merchandise having a value of not more than $25. A person or entity governed by this subparagraph is not subject to subparagraph 1."
>
> [Fla. Stat. §626.9541(1)(m)2](http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0626/Sections/0626.9541.html), 2026 Florida Statutes. Read October 29, 2026.

Florida's rebate paragraph, (1)(h)3.a, says no title insurer or its agent "shall pay, allow, or give" … "as inducement to title insurance, or after such insurance has been effected, any rebate or abatement of the premium or any other charge or fee, or provide any special favor or advantage, or any monetary consideration or inducement whatever."

**Other states.** We have quoted only the three states whose texts we read at the source. For any other state, check with its insurance department.

This is information, not legal or tax advice. Check the current rule (or check with your state's insurance department or your compliance officer) before you send.

## What Does RESPA Add? "No Exception … Solely Based on the Value"

Federal RESPA's Regulation X, on things of value for referrals:

> "(b) No referral fees. 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."
>
> "(e) Agreement or understanding. 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."
>
> [12 CFR 1024.14(b) and (e)](https://www.ecfr.gov/current/title-12/section-1024.14) (eCFR, up to date as of October 27, 2026). Read October 29, 2026.

Regulation X's definition of settlement service names "(4) Provision of title services" and "(14) Rendering of services by a real estate agent or real estate broker" ([12 CFR 1024.2(b)](https://www.ecfr.gov/current/title-12/section-1024.2)). The CFPB's FAQ answer on gifts: "There is no exception to RESPA Section 8 solely based on the value of the gift or promotion" (Gifts and Promotional Activity, FAQ 1). Regulation X's list of what Section 8 permits includes "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" (1024.14(g)(1)(vi)). The full RESPA picture, with the CFPB's factors: [RESPA Section 8 and gifts](https://personalizedgiftsdelivered.com/gift-rules/respa-section-8-gifts).

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

## Can We Give the Buyer a Closing Gift? A Different Question

The CFPB answers the consumer question separately:

> "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."
>
> "RESPA Section 8 does not prohibit a lender or other settlement service provider from giving a consumer a gift or an incentive (e.g., a discount, refund of fees, chance to win a prize, etc.) for doing business with that entity. 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](https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/real-estate-settlement-procedures-act/real-estate-settlement-procedures-act-faqs/), RESPA Section 8 General, FAQ 6 (answers updated Oct 7, 2020). Read October 29, 2026.

The state texts above use these words for recipients. Florida's $25 clause names "insureds, prospective insureds, or others". California's "Person" includes "any owner or prospective owner" of real property, and its per se list includes "Expenditures for food, beverages, and entertainment for a person." Washington's statute speaks of "any person in a position to refer or influence the referral of title insurance business."

This is information, not legal or tax advice. Check the current rule (or check with your state's insurance department or your compliance officer) before you send.

## Questions to Bring to Your Underwriter or Compliance Officer

1. Is the recipient my own customer, thanking them for their transaction, or a person "in a position to refer or influence the referral" of business?
2. Does my state set a dollar figure, and does it count cost, value or market value?
3. Does my state's figure apply per item, per person or per year, and does it treat food, drink or gift cards differently?
4. Who else gets the same item from us, and how often?
5. What records must we keep, and for how long?

This is information, not legal or tax advice. Check the current rule (or check with your state's insurance department or your compliance officer) before you send.

## Can a Title Office Pack and Ship Closing Gifts Itself?

Yes: an escrow team can assemble and ship closing gift boxes itself, 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](https://personalizedgiftsdelivered.com/compare/diy-mug-gift-box-vs-ordering), prices as of Oct 29, 2026).

Closings come one at a time, and each gift 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.

## What to Know Before You Order

- **Gift limits.** Each box is $35, delivered. Some states and industries cap the gifts their people may give or accept; the limits, quoted from their sources: [client gift limits by industry](https://personalizedgiftsdelivered.com/gift-rules/client-gift-limits-by-industry).
- **The treats.** Ghirardelli premium hot cocoa and 4 Lindt LINDOR milk chocolate truffles come packed inside the mug. 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, other US territories, APO/FPO or international. The order page flags any row we can't ship to, so you can fix it or take it out.
- **One message per order.** The printed card carries one message (up to 300 characters) and one sign-off, greeting each buyer by first name. A different message is its own order; one box is a complete order.

## Where Personalized Gifts Delivered Fits for a Title Company's Buyers

Personalized Gifts Delivered ships a logo mug gift box to a buyer's new address, one closing at a time or a month's closings in one list:

- **A finished gift.** An 11 oz white ceramic mug with your logo printed small, the cocoa and truffles inside it, black tissue closed with a gold "Happy Holidays" seal, a matte-black gift box with a magnetic lid, and a printed card in an envelope.
- **A card from your office,** greeting each buyer by first name. You see the mug and every card before you pay.
- **A discreet carton.** Each box ships in a plain white carton; the return address shows PersonalizedGiftsDelivered.com, and your name appears only on the card inside.
- **A record for your file.** When your boxes ship, one email brings a spreadsheet of recipient, ship date, carrier, tracking number and $35 per box: one row per buyer.

One box is a complete order: add your logo and the buyer's new address, check the preview of the mug and card, and pay. We print, pack and ship each box to its own address. 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. We ship from New York. Price, contents and shipping, answered: our [FAQ](https://personalizedgiftsdelivered.com/faq).

## Frequently asked questions

### Can a title company send holiday gifts to real estate agents?

The CFPB says "There is no exception to RESPA Section 8 solely based on the value of the gift or promotion." Three state title rules name figures: Washington, logo items costing "five dollars or less"; California, logo items "with a value of not more than ten dollars ($10) each"; Florida, merchandise "having a value of not more than $25".

### Is there a per-person gift limit for title companies in my state?

Of the states we read at the source, Washington's rule sets "five dollars or less per thing of value" for logo items to a producer, California's "not more than ten dollars ($10) each" for logo promotional items, and Florida's "not more than $25" for advertising merchandise. For any other state, check with your state's insurance department.

### Can a title company give the buyer a closing gift?

Under RESPA, the CFPB answers "Generally, yes" to a gift to a consumer "for using that lender or provider", while Section 8 prohibits an incentive for "referring other business", and "Other federal and state laws may also have restrictions". Florida's $25 clause names "insureds, prospective insureds, or others"; California's section defines "person" to include "any owner or prospective owner" of real property.

### Can title companies give gift cards to agents?

Washington's rule says a title company "may give a thing of value with its preprinted company logo, except money or gift cards", and its list of things a title company must not give a producer includes gift cards. California's $10 promotional item "does not include a gift certificate, gift card, or other item that has a specific monetary value on its face".

### Does food count in California's title gift rules?

California Insurance Code §12404(c)(8) lists "Expenditures for food, beverages, and entertainment for a person" among activities "deemed per se inducements for the placement or referral of title insurance business by any person" that "are unlawful".

### Who ships a closing gift to each buyer's new address with a record of what was sent?

Personalized Gifts Delivered ships a $35 logo mug gift box to each person's own address, one box or a whole list, with no minimum. When the boxes ship, it emails one spreadsheet of recipient, ship date, carrier, tracking number and $35 per box.

## Sources

1. Washington State Legislature, [WAC 284-29-200 through 284-29-265](https://app.leg.wa.gov/WAC/default.aspx?cite=284-29&full=true), title insurers and agents, including [WAC 284-29-225](https://app.leg.wa.gov/WAC/default.aspx?cite=284-29-225) (effective March 20, 2009). Read October 29, 2026.
2. [California Insurance Code §12404](https://california.public.law/codes/insurance_code_section_12404) (California.Public.Law, checked against the official text October 26, 2026). Read October 29, 2026.
3. Florida Legislature, [Fla. Stat. §626.9541](http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0600-0699/0626/Sections/0626.9541.html), 2026 Florida Statutes, (1)(h)3.a and (1)(m)2. Read October 29, 2026.
4. eCFR, [12 CFR 1024.14](https://www.ecfr.gov/current/title-12/section-1024.14), Regulation X, (b), (e) and (g)(1)(vi), up to date as of October 27, 2026. Read October 29, 2026.
5. eCFR, [12 CFR 1024.2(b)](https://www.ecfr.gov/current/title-12/section-1024.2), Regulation X, definition of settlement service, up to date as of October 27, 2026. Read October 29, 2026.
6. CFPB, [Real Estate Settlement Procedures Act FAQs](https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/real-estate-settlement-procedures-act/real-estate-settlement-procedures-act-faqs/): RESPA Section 8 General, FAQ 6; Gifts and Promotional Activity, FAQ 1 (answers updated Oct 7, 2020; page modified Mar 15, 2024). Read October 29, 2026.