what are the legalities on an reo transaction?

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what are the legalities on the way fees are paid on an reo transaction? on the fee agreements i have seen it states that none of the parties are licensed brokers. also today i was dealing with a refering party that is a licensed real estate agent and he said that his lawyer insisted that he must be paid directly from the hud to his broker in order for it to be legal? i thought that the direct sale of a bank owned property to an investor was a private transaction and did not fall under respa guidelines? anyone have some input on this?