Do any banks out there, large or small, refer denied Respa loans to an affiliate like a finance company making mortgage loans B paper? If so, how do you comply with the giving of the Affiliated Business Arangement Disclosure form? The regulation seems to say the form has to be given for a settlement service (loan) to the client before referral and the final rules do say that the form must have one signature. In a perfect world, where the client comes in and is told he is denied, this is no problem because you could get him to sign the form and put in the deniel file of the bank. But in most real life scenerios, the customer is mailed an adverse action form and does not come back into the bank. In the Respa Act itself, under Section 8, there is a provision that says you can verbally give a abbreviated ABAD as long as you mail the form within 3 business day and document on the form their verbal consent. But in the Act, it does say at all times the form must be signed. Even here, you could get signed later with closing with the new entity but if they deny it, it will never get signed. This is probably a risk issue, but how do other banks refer to an affiliate for a loan and get the ABAD signed. Or do you not get it signed. Thanks. Janie