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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
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.
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 →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.
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"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
1. REGULATORY LANDSCAPE: This provision directly implicates RESPA Section 8 and its affiliated business arrangement disclosure requirements, enforced by the Consumer Financial Protection Bureau. RESPA requires that affiliated business arrangement disclosures be provided at or before the time of referral, on a separate disclosure form, and that consumers be informed they are not required to use the affiliated provider. Embedding this disclosure in master terms of use rather than providing it separately at the point of referral may warrant evaluation under CFPB guidance on RESPA Section 8 compliance. 2. GOVERNANCE EXPOSURE: High. The referral network spans mortgage origination (Zillow Home Loans), title and escrow (Zillow Closing and Escrow Services CA and five Spruce entities), and insurance (Zillow Insurance Services), covering the primary settlement service categories regulated under RESPA. The disclosure of financial benefits flowing to employees of the referring entities may also implicate state licensing obligations for mortgage and real estate professionals. 3. JURISDICTION FLAGS: The Spruce entities named cover Louisiana, Alabama, Southwest, West, and general U.S. markets, indicating multi-state operations each subject to separate state title insurance and settlement services regulations. California's Zillow Closing and Escrow Services entity is separately named, reflecting California-specific licensing requirements. State-level RESPA analogs and consumer protection statutes in each operating jurisdiction may impose additional disclosure obligations. 4. CONTRACT AND VENDOR IMPLICATIONS: Real estate professionals, brokers, and lenders who refer clients to Zillow's Services and who may receive reciprocal referrals from Zillow-affiliated entities should assess RESPA Section 8 compliance independently. The financial benefit disclosure to Zillow Group employees may also interact with RESPA's prohibition on unearned fees and kickbacks. 5. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should evaluate whether the terms-of-use placement of this disclosure satisfies RESPA's requirement for a separate, timely affiliated business arrangement disclosure at the point of referral. Organizations receiving or making referrals involving Zillow-affiliated settlement service entities should conduct RESPA Section 8 due diligence and confirm that consumer-facing disclosure practices meet regulatory standards.
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.
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 …
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