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#414439 - 08/26/05 01:11 PM Upfront Disclosures
sansan Offline
100 Club
Joined: Apr 2004
Posts: 161
The hat rack
New York mortgage brokers are telling our new Ops manager that they do not have to provide any federal or state upfront disclosure other than the GFE. They are stating that since they are not the "lender" it is not their responsibility. I can't find any reg that backs this up? If what they are saying is true, can someone please direct me to the appropriate reg? Thanks!

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#414440 - 10/12/05 07:20 PM Re: Upfront Disclosures

commercial loan prepayment penalty

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#414441 - 10/14/05 03:38 PM Re: Upfront Disclosures

Regulation Z requires that in a residential mortgage transaction subject to the real estate settlement procedures act (12USC 2601 et seq), the creditor shall make good faith estimates of the disclosures required by 226.18 before consummation, or shall deliver or place them in the mail not later than three business days after the creditor receives the consumer's written application, whichever is earlier. Disclosures may be delivered or placed in the mail not later than three business days following the receipt of a consumer's application when the application reaches the creditor by telephone, or through an intermediadiary agent or broker. So you need to redisclose 3 days after you get the application from the broker.

Hopefully this will help you with your question.

Happy compliance!

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