The bank receives a loan from a Broker, and the Broker has given the applicant their own Affiliated Business Arrangement and required provider notices. The Bank's Affiliated Business Arrangement Notice and required providers are different from the Broker's. Does the Bank still have to give the applicant its AfBA and Req. Prov. Notice, or is the Broker's disclosure sufficient?
Thanks,
Leslie

Section 3500.7 provides in (b) that the mortgage broker must provide a good faith estimate within three days of receiving a loan application based on his or her knowledge of the range of costs. There are no provisions for providing subsequent GFEs, however, most regulators I have spoken with suggest that it is probably good sound business practice that if the terms or disclosure of required providers changes significantly to provide a subsequent GFE.

A D,
thanks for your response. The GFE itself is not the issue. The issue has mostly to do with the AfBA. For example, the Broker is affiliated with XYZ Settlement Service and we are affiliated with ABC Title. We are also affiliated with DEF Insurance agency, and the Broker is not. So, do we need to give our disclosure, or is that just a "suggested" practice and not a mandatory one?
Leslie

You bring up a good point. While the afba requirements can be satisfied at the time of the good faith estimate, you must disclose on a separate piece of paper no later than the time of each referral. (Section 3500.15) So I stand corrected - in the case of afba's, you must give the Affiliated Business Arrangement Disclosure Statement for the providers you require

The AfBA obligation runs to any settlement service provider. The fact that the broker gave disclosures does not cover your additional relationships. You have to disclose those. As Allan explained, you should provide this on a separate piece of paper because the GFE has already been given.