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#1807543 - 04/24/13 01:44 PM AfBA
wanted Offline
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wanted
Joined: Oct 2001
Posts: 99
United States
Is this an affiliated business arrangement? Bank loan officer refers title work services to a law firm owned by spouse.
Does bank have a business relationhip with provider?

Referring Party: bank
relationship??: spouse of bank loan officer??

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RESPA
#1807575 - 04/24/13 02:35 PM Re: AfBA wanted
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Yes and it also sounds like a conflict of interest.
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#1807650 - 04/24/13 04:16 PM Re: AfBA wanted
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
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#1807787 - 04/24/13 07:36 PM Re: AfBA Dan Persfull
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wanted
Joined: Oct 2001
Posts: 99
United States
Second part of question- The law firm owned by the spouse is not on the bank's Settlement Services Providers list and a customer chooses to use the spouse's law firm. Does the AfBA diclsoure need to be given if customer chooses-no referral?

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#1807811 - 04/24/13 08:00 PM Re: AfBA wanted
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The consumer doesn't have an option to choose "no referral". You either made the referral or you didn't. I'm curious how you will document a referral was not made, especially if the consumer chooses the law firm.
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