I've been wrapping my brain around a couple of issues and have come to a conclusion, but I wanted to see what others think about the situation.

Scenario: Financial Institution A is unable to offer certain loan programs, such as VA, to their customers. In order to keep customers happy, provide good customer service, etc., they utilize a relationship with Financial Institution B who subsequently does all the loan documents, provides the funds, and originates the loan in their name. Financial Institution B, because they are responsible for all loan documents, issues an ABA on behalf of Financial Institution A because they have an affiliated business that is a Title company. Financial Institution B recently started contracting with an AMC for the appraisals associated with such loans. The AMC is an affiliate of Financial Institution B.

My understanding is that Financial Institution A operates as a broker in this transaction and brokers are also covered under the ABA.

Questions: What solutions/disclosure requirements can you think of based on this scenario? Does Financial Institution B create two separate ABA disclosures (one that deals with A and the Title Company and one that deals with B and the AMC)? Does Financial Institution B then need to mark the affiliate of Financial Institution A as the "preferred" provider on the SSPL and Section C of the LE and treat as a 10% tolerance standard? Or, because Financial Institution A really has no say in who Financial Institution B uses as their preferred provider, then B still populates the SSPL just like they would for any other loan?

No takers?

You can list more than one affiliate on the AfBA disclosure. Creating separate disclosures would be an internal decision.

As discussed in previous threads if the service is performed by an affiliate the tolerance is zero regardless if the provider is on the SSPL or who chose the provider.

Thanks Dan. The issue with using one disclosure is that there are two different "lenders," rather than multiple affiliates of the same lender. Where do you fit the additional lender/broker on the form?

Also, with the 0% tolerance rule, how does that apply to the affiliate of Financial Institution A? That is where the issue comes about in this situation. How do we treat the affiliates of the community bank or credit union that brokers the loan over to us? Are they given the same consideration as if it was our own affiliate, or are they not really treated as part of the transaction because they are not an affiliate of the actual lender, but rather of the "broker?"