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#2143677 - 08/25/17 05:49 PM Affiliated Business Notice used as SSPL?
Truffle Royale Offline

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Can an affiliated business disclosure be used in lieu of a settlement service provider list?

There's language on the one I'm looking at that reads:
Quote:
There are frequently other settlement service providers available with similar services. You are free to shop around to determine that you are receiving the best services and the best rate for these services.

The last sentence above makes me feel like the answer to my question would be yes.

But then right underneath a breakout of costs at the affiliate it reads:
Quote:
ACKNOWLEDGEMENT
I/we have read this disclosure form and understand that (bank) is referring me/us to purchase the above-described settlement service(s) and may receive a financial or other benefit as the result of this referral.
(borrower signature)

Does this negate the SSPL language above and change it into a referral?

Can I take a document with this wording for both the affiliated business notice AND the SSPL?

Thanks to anyone who uses these or has knowledge of how they work.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2143688 - 08/25/17 06:23 PM Re: Affiliated Business Notice used as SSPL? Truffle Royale
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The disclosures serve two separate purposes. And don't forget that an AfBA that triggers the AfBA disclosure under RESPA may not even meet the definition of affiliate for the purposes of the TRID rule. While you don't have to use the sample SSPL that's in the appendix, you do need to include the information that's on the form. I think trying to do a mashup of the two disclosures can only create confusion.

I am all for cutting down on paper, and applaud the inclusion of the appraisal copy disclosure on the loan estimate and similar combinations. But this one isn't one I can recommend.
Last edited by John Burnett; 08/25/17 06:27 PM.
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#2143689 - 08/25/17 06:26 PM Re: Affiliated Business Notice used as SSPL? Truffle Royale
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,398
Thanks, John. You confirmed my thought process which is what I needed before I broached this with the issuer.

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