Our bank recently signed an agreement with a mortgage company. We will refer customers to this mortgage company when they are seeking traditional financing (we only offer short term solutions,not any traditional 30-year products). We'll be compensated 35 bps for each loan that closes. The payment from the mortgage company will be monthly and will be based on the total of closed loan referrals for the month.
I have reviewed HUDs 1999 'broker rule' letter and we'll be performing enough services to be compliant with that (and will be doing more than counseling-type services). We'll also only have MLO's handle the customer interaction and make the referral. The mortgage company is not an affiliate.
What are my disclosure requirements to the applicant regarding the fact that we'll be getting a spiff if their loan closes? Do I have any steering concerns since we're only doing business with one company?