I found the information below on "Attorney Controlled Title Agencies". In it, it states that "an attorney must disclose an AfBA relationship in circumstances in which a RESPA disclosure is not required...e.g., cash or commercial.
Would I substitute "bank" for "attorney" and require our title company to provide the AfBA on commercial loans?
Attorney Controlled Title Agencies:
While the RESPA AfBA disclosure form is probably sufficient for ethics compliance, an attorney must disclose an AfBA relationship in circumstances in which a RESPA disclosure is not required...e.g., cash or commercial transactions, or in which the attorney's interest is less than one percent. Also, although RESPA does not require it, if the attorney requires the use of the adjunct title agency, ethically it would be best to disclose the required use to the client. A disclosure is required "prior to closing" that an attorney is not personally searching the title to property and is, instead, relying on the work product of a title agency (whether an AfBA or not).