I read through the thread from December '01 about weblinking and RESPA and have a followup question.
A real estate broker that is affiliated with a mortgage brokerage company we control wants to install a link on its real estate web site to the mortgage broker site. To me this sure looks like a referral so the AfBA disclosure is required. RESPA, however, at section 3500.15 states, "The disclosures must be provided on a separate piece of paper no later than the time of each referral . . ."
RESPA's reference to a separate piece of paper seems to preclude being able to give the AfBA disclosure electronically "at the time of the referral."
Anyone have any experience with or thoughts about this?
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My opinions are not legal advice and are worth what you paid for them.