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#503153 - 02/23/06 12:32 AM Affiliated Business Arrangement Disclosure
clarizar Offline
100 Club
Joined: Apr 2005
Posts: 152
We have a HELOC product that we are offering at no cost to the borrower (we are paying for all the customary closing costs)-- are we still required to provide the ABA disclosure?

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Lending Compliance
#503154 - 02/23/06 01:28 AM Re: Affiliated Business Arrangement Disclosure
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
Yes. There is no exemption for different product types for this disclosure. You could try some clarifying language such as "paid by lender" where you list the costs.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#503155 - 06/27/06 03:32 PM Re: Affiliated Business Arrangement Disclosure
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
We are partnering with our mortgage affiliate also on a HELOC offering. They will do the first mortgage and the bank is doing the 2nd for the downpayment. The catch is that the mortgage person is a "dual employee" of both the mortgage company and the bank. The HELOC will be done in the bank's name but the dual employee will close the loan at the same time they do the first mortgage. In this case, do we have a affiliate business arrangement since the person is a "dual employee"? Another related question is if we do an AfBA disclosure, the mortgage company says that since there would be no fees on the HELOC that the only thing that would be disclosed would be the affiliate relationship and there would be nothing indicated under providers and charges. I'm going back through the appendix but so far haven't come across this. Thank you.

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