Williams promised the buyers, “I’ll give you a $400 gift card at closing,” and when they were filling out their loan application, Williams added $400 to his commission, which increased the loan amount by $400. CLIENT 1 then asked, “What’s that $400 for?” and Williams replied, “That’s for the gift card I’m going to give you.” The client then politely said, “Well, why don’t we just forget the card, and leave that off the loan.”