section 8(c) goes on to list examples of permissible payments and these examples emphasize that such payments must be reasonable and for actual services rendered. the cfpb found that msa participants often failed to provide the services called for under those agreements and that those parties paying for the services acquiesced in such behavior. the cfpb concluded that “when services promised under an msa are not performed, but payments are being made, a reasonable inference can be drawn that the msa is part of an agreement to refer settlement service business in exchange for kickbacks.” building on that inference, the agency went on to advise that msas pose “risks that are greater and less capable of being controlled” by parties to such agreements and that monitoring vendor compliance with msa mandated services is “inherently difficult,” even when the msa contract had been “carefully drafted to be technically compliant with .