rl, Our bank is in a similar situation, in that, we are looking at a loan broker relationship where the lender makes the credit decision and we serve in the capacity of origination services with a flat fee. No matter the product, we make the same fee. For example, the applicant is
self-employed, the lender has only one product that we offer, would an anti-steering disclosure be required under 1026.36(e). The lender is requiring an anti-steering disclosure. What would it include as there is only one product available to the applicant. Management is asking do
we provide the anti-steering disclosure or ask the lender to remove the requirement from the agreement. Thanks.