In response, Irwin contended that its payment of YSPs to mortgage brokers were not kickbacks or referral fees, but, rather, that the payments fell within the safe harbor of RESPA, 12 U.S.C. ?? 2607(c), which provides that [n]othing in this section shall be construed as prohibiting ... the payment to any person of a bona fide . . . compensation or other payment for goods or facilities actually fur