Definition
Co-mingled Funds: Money from multiple parties combined into a single account or payment stream. In advertising, co-mingled funds occur when one party pays for ads on behalf of others, creating regulatory and audit concerns.
Why This Matters in Real Estate
Under RESPA and similar regulations, settlement service providers cannot provide things of value (including advertising) in exchange for referrals. Co-mingled advertising funds can be construed as such payments.
How Walled Garden Uses This Concept
Walled Garden eliminates co-mingled funds entirely. Each agent controls their own advertising budget and pays directly via their own payment method. No co-mingled funds exist within the system.