Section 03 · Real Estate Division

Real Estate Division Blueprint

Agent compensation tiers, eXp vs Real vs TruLux model comparison, revenue share architecture, RESPA compliance, ISA system, and NAR settlement impact.

🏢
Brokerage Model Comparison: eXp vs Real vs TruLux
2025–2026 Data
eXp Realty
eXp Realty
Cloud brokerage, publicly traded (EXPI)
Split80/20 (agent/eXp)
Annual Cap$16,000
Post-Cap Fee$250/deal ($75 after $5K)
Monthly Cloud Fee$85/month
Revenue Share Tiers7 tiers
Tier 1 Rev Share3.5% of GCI (up to ~$4K/yr)
ICON ProgramUp to $16K EXPI stock back
Team Models4 types (self-org, standard, mega, partnership)
One Real MortgageNo equivalent
Real Brokerage
The Real Brokerage
Public (REAX), faster-growing model
Split85/15 (agent/Real)
Annual Cap$12,000
Annual Brokerage Fee$750/year
Post-Cap Fee$285/deal ($129 Elite)
Monthly Fee$0 (no desk fee)
Revenue Share Tiers5 tiers
Tier 1 Rev Share5% of GCI (up to $4K/yr)
Willable Rev ShareYes — after 3 years (60%), 5 years (100%)
One Real MortgageYes — agents can dual-license as LOs
TruLux Model
TruLux (Recommended)
Proprietary, franchise-ready design
Company-Lead Split50/50 (agent/TruLux)
Self-Generated Split70/30 (agent/TruLux)
Senior Agent Split80/20 (agent/TruLux)
At-Cap Split85–100% (post-cap)
Revenue Share Pool20% of company dollar → 3 tiers
Tier 1 Rev Share5% of company dollar
Cross-Division BonusExtra 1% when RE + mortgage both close
Phantom Equity3–4 year vesting for retention
Vertical IntegrationFull: RE + Mortgage + Construction
💰
Commission Split Architecture
Production-Based Tiering
50/50
Company-Provided Leads
TruLux funds lead gen, ISA, CRM, and admin. Agent's GCI under $75K annually.
70/30
Self-Generated Leads
Agent sources their own business through sphere, referrals, or personal marketing.
80/20
Senior/High Production
Agent's annual GCI exceeds $150K on company leads. Earned through production.
Annual GCI ThresholdCompany-Lead SplitSelf-Generated SplitAvg Transaction ValueAvg TruLux Retained/Deal
$0–$75K GCI50/5070/30~$8,375$4,187 (company lead)
$75K–$150K GCI55/4575/25~$8,750$3,937 (company lead)
$150K+ GCI60/4080/20~$9,000$3,600 (company lead)
Post-cap agent85–100%85–100%—Flat transaction fee only
📊
NAR Settlement Impact (August 2024): Post-settlement data (Q1–Q2 2025) shows buyer agent commissions actually rose slightly to 2.40–2.43% nationally. Sellers continue offering BAC in most transactions. Primary impact is requiring written buyer representation agreements before showings — adding administrative friction but not compressing commissions. Train agents to present buyer representation value early and include signing in automated CRM workflows.
🔄
TruLux Revenue Share Design
Borrowing from eXp + Real Architecture

TruLux doesn't need to be publicly traded or have 100,000 agents to offer a compelling revenue share. Borrow the architecture from eXp and Real while keeping it proprietary and franchise-ready.

TierRelationshipRev Share RateQualification
Tier 1Agents you directly recruit5% of company dollarMin $3K company dollar/quarter
Tier 2Agents they recruit3% of company dollarSame
Tier 3Next level down1% of company dollarSame
Cross-Division BonusWhen RE + mortgage close same clientExtra 1% (both sides)AfBA compliant
Design Principles
  1. 1. Pool Funded Correctly: Allocate 20% of company dollar (not agent commission) — same as eXp's model. Never pay from agent splits.
  2. 2. Qualification Floor: $3,000 minimum company dollar per quarter to remain eligible — prevents gaming with one-deal-per-year "sleeper" recruiters.
  3. 3. Willable at Year 3: Following Real Brokerage's model — rev share becomes willable after 3 years of qualifying production, creating 10–20 year retention.
  4. 4. Phantom Equity Overlay: Top producers (Level 4–5) receive profit-sharing units with 3–4 year vesting schedules. Misalignment in non-compete is unenforceable in FL, but equity vesting works.
⚖️
RESPA Compliance for the Three-Vertical Model
Critical — Non-Negotiable
🚨
RESPA Section 8(a) prohibits any fee, kickback, or thing of value for referral of settlement service business. TruLux's three-vertical model (RE referring to mortgage) is a primary CFPB enforcement target. Penalties: up to $10,000 per violation plus potential imprisonment. The AfBA exception is available — but only if three simultaneous conditions are met.
  1. 1
    Written AfBA Disclosure Required: Must be provided to every consumer before or at the time of referral. Must specify the ownership/financial relationship between TruLux RE and TruLux Mortgage, and provide estimated charges. Consumer must sign. Retain all signed disclosures for 5+ years.
  2. 2
    No Required Use: Consumers cannot be required to use TruLux Mortgage or any affiliated service. Every referral must explicitly state: "You are free to choose any mortgage lender." This must be said and written. Do not imply that using in-house mortgage is necessary to receive full service.
  3. 3
    Ownership-Proportional Distributions Only: The only permissible payment between TruLux RE LLC and TruLux Mortgage LLC is a return on ownership interest — proportional to actual ownership percentage. Distributions can never be correlated with referral volume. Do not pay agents a per-referral bonus for sending clients to mortgage.
✅ Permitted
  • ✓ Referring clients to affiliated mortgage with proper AfBA disclosure
  • ✓ Operating RE and mortgage as separate LLC entities under common ownership
  • ✓ Distributing profits proportional to ownership stake (regardless of referrals)
  • ✓ Traveus acting as both agent and LO on the same transaction (with full disclosure)
  • ✓ Marketing mortgage and real estate services together under TruLux brand
🚫 Prohibited
  • ✗ Paying agents a $X bonus per client referred to TruLux Mortgage
  • ✗ Requiring buyers to use TruLux Mortgage to access TruLux listings
  • ✗ Profit distributions that increase or decrease based on referral counts
  • ✗ Implied steering — "we prefer to work with buyers pre-approved through our lender"
  • ✗ Operating without separate books, staffing, and arm's-length transactions
📞
ISA System: Qualifying & Routing Leads
Ken Pozek's Exact Model
ISA Compensation Structure
ModelBasePer AppointmentClosing Bonus
Philippines ISA$800–$1,100/mo$25–$50Optional
US-Based ISA$2,000–$2,500/mo$75–$1007% of GCI at close
US Agency Hire$40K–$65K/yr totalIncludedIncluded
💡
Pozek's ISA Script: "Who would Ken want you to work with is Michelle, because Michelle actually lives in Windermere and she is his absolute expert in that area. When's a great time for Michelle to reach out?" This script resolves 90%+ of "I only want to work with Ken" objections — it signals personal curation, not routing.
LPMAMA Qualification Framework
  1. L — Location: Where are you looking to buy/sell?
  2. P — Price: What is your target budget range?
  3. M — Motivation: What's driving your move? When do you need to be there?
  4. A — Agent: Are you working with a Realtor currently?
  5. M — Mortgage: Have you spoken with a lender? Pre-approved?
  6. A — Appointment: Let's set up a brief consultation with one of our specialists.
📊
Team Cost Modeling
Monthly Overhead by Team Size
5-Agent Team
Agent fixed costs (MLS, dues)$1,250
Office space$2,000
ISA (1 Philippines)$1,200
Transaction coordination$2,800
CRM/Tech$500
Marketing budget$2,000
Admin/bookkeeper$1,500
Insurance/misc$750
Total Monthly$12,000
Break-even: 2 deals/month @ $6K net/deal
10-Agent Team
Agent fixed costs$2,500
Office space$3,500
ISA (1 US + 1 PH)$5,500
Transaction coordination$4,000
CRM/Tech$800
Marketing budget$4,000
Admin + TL salary$8,000
Insurance/misc$1,100
Total Monthly$29,400
Break-even: 5 deals/month @ $6K net/deal
20-Agent Team
Agent fixed costs$5,000
Office space$5,000
ISA (2 US + 2 PH)$11,000
Transaction coordination$7,000
CRM/Tech$1,500
Marketing budget$8,000
Admin + Ops Mgr$19,000
Insurance/training/misc$2,800
Total Monthly$59,300
Break-even: 10 deals/month @ $6K net/deal