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#1551838 - 05/16/11 07:24 PM Affilated business arrangement
wanted Offline
Member
wanted
Joined: Oct 2001
Posts: 99
United States
Bank's attorney is a director of bank. Bank uses this attorney as a closing agent. Attorney is listed on the AfBA.
If bank customer uses another attorney in town, should bank still give the AfBA?

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Lending Compliance
#1551941 - 05/16/11 08:21 PM Re: Affilated business arrangement wanted
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The AfBA disclosure is only required if a referral is made.

Attorney is listed on the AfBA.

If you are referring to your list of service providers then you would need the AfBA disclosure at the time you provide the GFE because you are making a referral by listing them. This is addressed in the RESPA 4/2/10 FAQs.
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The opinions expressed are mine and they are not to be taken as legal advice.

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