Please forgive me for asking something that may be obvious to others but I am unsure from reading RESPA whether we need to complete section "B" or not. Section B states: "Set forth below is the estimated charge or range of charges for the settlement services of an attorney, credit reporting agency or real estate appraiser, that we, as your lender, will require you to use..."

I've gotten feedback from another compliance person who joined us recently from another company that section B should only be completed when we actually have an affiliated relationship with the credit bureau, attorney or real estate appraiser. The feedback I was given by that person is that the purpose of the disclosure is only to disclose affiliated relationships and therefore since we don't have an affiliated relationship with these service providers other than the fact that we do select them regularly, then section B does not apply and should be blank.

I am not reading the instructions in that manner but I am frequently too conservative in interpretation and just want to get it right. My reading of the instructions is that if we do not allow the borrower to select the credit bureau or appraiser for instance, we are required to complete this section even if the only relationship we have with them is to contract for the appropriate third party service for the fee that unaffiliated company charges. Am I just about to run into a forest that is hidden by all the trees?

Part A is for affiliate service providers that you allow the consumer to choose. Part B is for the affiliate service providers that you do not allow them to choose.

I don't remember the last time I had to provide an AfBA Disclosure.

Thanks Dan. You are lucky to not have to mess with these. Looks like I was wrong but I'm actually very glad to be wrong because that is much easier. Thanks for your very educated input as always!