Evaluate the following action below and determine whether there is RESPA violation.

First American Title Insurance acquired a 17.5% ownership interest in Tower City Title Agency for $2 million and, in the same transaction, Tower City agreed to refer future title insurance business to First American. First American also entered into similar transactions with various other title agencies. In each of these transactions, First American paid the title agencya lump sum of money in exchange for (1) a minority ownership interest in the title agency and (2) the title agency's agreement to refer future title insurance business to First Ameri-can. Denise Edwards, a homebuyer, purchased a home in Cleveland and used First American. She brought suit alleging the referral program was prohibited by RESPA. [Edwards v. First American Corp., 798 F.3d 1172 (9th Cir. 2015).]