I assume the "Anti-Steering Disclosure" is one that your LOS has available for you to use as there isn't a regulatory requirement for such form. That said, the point of such disclosure is to reduce steering risk by "proving" that the customer directed the product selection and wasn't unjustly led to a product that is less beneficial for them. So, if you are using the disclosure in some cases, I'm not sure why you wouldn't use the disclosure in a case where you aren't putting the customer in a secondary market product, which often has a lower rate and more flexible terms than portfolio loans.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com