An escrow company sponsors an annual real estate conference and pays all registration costs ($1,500 per attendee) for real estate agents from four local brokerages. The conference includes 20 hours of CE credit courses taught by recognized industry experts. In evaluating this arrangement under RESPA Section 8, which factor would MOST support a finding that the payment is permissible?

The CE credits have educational value that independently benefits the agents' professional development The conference registration cost equals less than $500 per agent per year when averaged over all agents in the market The payment is spread across multiple brokerages, diluting the referral-inducement concern The conference is open to all real estate agents in the region, not only those who refer to the escrow company