For our mortgage loans, we provide a disclosure describing all the products we offer....not rates.....just terms...such as with VA the customer can get up to 100% financing, and that a home improvement loan lien is established using a contractor and for a home equity loan, only 80% of the value can financed under state law.

Our new Mortgage Loan Manager wants to do away with the form. Compliance likes the form because it shores up fair lending efforts and steering.

Any thoughts on this? We want to present our best arguments to the manager.

Many banks I know of are going towards the additional disclosures for the reasons you indicated - clarity and openness to the customer. Also, if they have a brochure someone else might see it and think "ABC has the products I'm looking for". Look at websites of the major players - they list everything in their arsenal. Also UDAAP may be an issue if the applicant does not receive information about a better suited product.