Can I ask a question about Section B on the Affiliated Business Arrangement notice? Assume your bank has an affiliated business arrangement with a firm, and you correctly disclose it in Section A. It's been done correctly, never any criticism. However, the mortgage department was using Section B to disclose the credit bureau company name, even though the credit bureau isn't affiliated in any way; it's one of the big 3. Mortgage department says they have to put the credit bureau company name in Section B. Some were even putting the name of an un-affiliated appraiser. They were advised not to, because the Affiliated Business Arrangement notice is just to disclose affiliates! Which is correct?

If a service provider is not an affiliate as that term is defined in the regulation then they should not be listed on the AfBA Disclosure.

Thank you, Dan. I agree, it's just a long-standing practice that we're trying to change. Appreciate the response!

As for "we've always done it this way", tell them "rules change, get used to it"!!!