If we have a broker that sends us a package out of the blue for a commercial loan request, are we required to accept it? Can we simply say that we don't accept broker referrals and send it back? As long as I've been in banking I guess I've never really spent much time thinking about this. But if we do accept it and review it and decline it, then we're obligated to send an AAN if we decline (or communicate our AA reasons to the broker and rely on them to do it) right? If we just kick it back would we have potential discrimination issues? Can we accept packages from brokers that are known to us but not from those who are not?

With all of the requirements regarding joint intent, etc. it just seems like there's more and more risk in accepting these deals from a third party.

You are not required to accept any deals from brokers if you so choose. Prior to accepting any broker deals, the bank should enter into a written agreement outlining each parties responsibilities.

Thanks!