We (bank) recently added a mortgage broker to our holding company. As part of this program, we (bank & broker)have created new ARM products - with rates that can only be received if the loan applicant and the loan, which, if accepted by the bank, will be kept in our internal loan portfolio when it comes back to us. FYI - some loans brokered will still go to the secondary market, but that's for another time. My question is - who is responsible for giving the Adjustable Rate Loan Program Disclosure? When a mortgage customer comes in to the bank, we will tell them our in-house loan rates, and give them the option of going on the secondary market or of going through the broker to come back to us (with these lower rates) with a loan package for approval. We have the ARM disc. for our internal adj./but since the ONLY WAY a customer can obtain these other rates is through the broker, would the broker be responsible for giving the ARM disclosure for the program the customer chooses or want to look at? The broker at NO time makes the lending decision.