Provision record
Zillow · Zillow Terms of Use · View original document ↗

Affiliated Business Relationship and Referral Disclosure

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Document Record

What it is

The agreement discloses that eleven named Zillow-affiliated entities, including mortgage lending, title, escrow, and insurance subsidiaries, may refer users to each other, and that such referrals may generate financial or other benefits for the referring entities, their parent companies, and employees.

This analysis describes what Zillow's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision constitutes the affiliated business arrangement disclosure required under RESPA for settlement service provider referrals. The disclosure names eleven specific affiliated entities spanning mortgage, title, escrow, and insurance services, and states that referrals among them may produce financial benefits for the Zillow Group corporate structure.

Interpretive note: Whether the placement of this disclosure within master terms of use satisfies RESPA's separate, point-of-referral disclosure requirement is a compliance question that depends on CFPB guidance and enforcement posture.

Recent Activity

This document changed recently

Medium Jul 13, 2026

The updated terms establish explicit consent for Zillow to contact you through email, phone calls, text messages, and in-app features using automatic dialing systems and prerecorded voices. These communications may include advertising or marketing offers alongside transactional messages. Message and data rates may apply depending on your carrier, and contact frequency will vary based on your account activity. You can opt out of text messages at any time by replying STOP, and calls with Zillow employees may be recorded for quality control and internal business purposes.

View change record →

Clause Stability Mostly Stable

1
Change
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen
This clause has changed once in 4 months of monitoring.

Change history

added Jul 13, 2026

New disclosure of affiliated business entities and referral relationships clarifies financial incentives and interconnected services within the Zillow ecosystem.

View full change record →

Consumer impact (what this means for users)

Under this clause, when Zillow connects a user to mortgage, title, escrow, or insurance services offered by affiliated entities, the referring company may receive a financial benefit. The agreement states that users are not required to use affiliated providers and may shop for settlement services independently, though the disclosure is embedded in the master terms rather than presented separately at the point of referral.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
This is to give you notice of business relationships among the following providers. Zillow, Inc. ("ZINC," which operates Zillow.com); Zillow Group Marketplace, Inc. ("ZGMI"); Zillow Homes, Inc. ("ZHO"); Zillow Home Loans, LLC ("ZHL"); Zillow Insurance Services, LLC ("ZIS"); Zillow Closing and Escrow Services CA, Inc ("ZCS CA"); Spruce Land Services LLC ("Spruce"); Spruce Land Services West LLC ("Spruce West"); Spruce Land Services Southwest LLC ("Spruce Southwest"); Spruce Land Services of Louisiana, LLC ("Spruce Louisiana"); and Spruce Land Services of Alabama, LLC ("Spruce Alabama") are affiliated companies and each may refer to you the services of another. Because of these relationships, any referrals of you by any of the Zillow Companies may provide the referred company, its direct or indirect parent (including Zillow Group), and our respective employees with a financial or other benefit.

Excerpt from Zillow's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →

Provision details

Document information
Document
Zillow Terms of Use
Entity
Zillow
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014235
Document ID
CA-D-00231
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2cb652db3ff156ae7892f761fcf07d4f6bda63450f663b09a98fb4d0fdd82949
Analysis generated
July 9, 2026 05:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Zillow
Document: Zillow Terms of Use
Record ID: CA-P-014235
Captured: 2026-07-09 05:04:11 UTC
SHA-256: 2cb652db3ff156ae…
URL: https://conductatlas.com/platform/zillow/zillow-terms-of-use/provision/CA-P-014235/affiliated-business-relationship-and-referral-disclosure/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Zillow's Affiliated Business Relationship and Referral Disclosure clause do?

This provision constitutes the affiliated business arrangement disclosure required under RESPA for settlement service provider referrals. The disclosure names eleven specific affiliated entities spanning mortgage, title, escrow, and insurance services, and states that referrals among them may produce financial benefits for the Zillow Group corporate structure.

How does this clause affect you?

Under this clause, when Zillow connects a user to mortgage, title, escrow, or insurance services offered by affiliated entities, the referring company may receive a financial benefit. The agreement states that users are not required to use affiliated providers and may shop for settlement services independently, though the disclosure is embedded in the master terms rather than presented separately at …

Is ConductAtlas affiliated with Zillow?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Zillow.