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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Loan Originator Compensation Rule Affliated Business Disclosures
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#1849049 - 09/05/13 04:15 PM Affliated Business Disclosures
lrobbins Offline
Member
Joined: Sep 2013
Posts: 90
Our bank's secondary market department will no longer be using an affiliate(bank owned title company) for title work/insurance etc, however the bank will continue to use an affiliate for "in house" mortgage loans. Should the bank continue to provide an Affiliated Business Disclosure to our secondary market borrowers?
Last edited by lrobbins; 09/05/13 04:16 PM.
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Loan Originator Compensation Rule
#1849084 - 09/05/13 04:52 PM Re: Affliated Business Disclosures lrobbins
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
the bank will continue to use an affiliate for "in house" mortgage loans

That is a referral to an affiliate. Nothing in that section of RESPA has changed.
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#1849146 - 09/05/13 06:11 PM Re: Affliated Business Disclosures lrobbins
lrobbins Offline
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Joined: Sep 2013
Posts: 90
Thank you.

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#1860646 - 10/11/13 02:19 AM Re: Affliated Business Disclosures lrobbins
BTJ Offline
Member
Joined: Sep 2007
Posts: 83
Referring a transaction to a specific loan originator (when personal financial characteristics are known) or to a creditor who is not an employee of the organization will subject the individual to be a loan originator under TILA, subject to LO Compensation & Qualification Requirements.

There does not appear to be an apparent exemption for affiliate relationships for the LO Definition. Am I missing anything?

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