Brokered Loans

We have a situation where we are doing business with brokers...when these loans are getting QC review, we are sometimes finding disclosures not getting to the applicant or not getting to the applicant in the time frames required. The manager of the department is responding to these issues by saying because they are brokered loans, there isn't anything we can do and/or we aren't responsible for these compliance issues. I tend to disagree, but was wondering if anyone had any input or could direct me to a source that can give me some info?

Thanks in advance.

Here is an excerpt from RESPA on the GFE:

24 CFR 3500.7(b)
"In the event an application is received by a mortgage broker who is not an exclusive agent of the lender, the mortgage broker must provide a good faith estimate within three days of receiving a loan application based on his or her knowledge of the range of costs. As long as the mortgage broker has provided the good faith estimate, the funding lender is not required to provide an additional good faith estimate, but the funding lender is responsible for ascertaining that the good faith estimate has been delivered. If the application for mortgage creidt is denied before the end of the three business day period, the mortgage broker need not provide the denied borrower with a good faith estimate."

In my experience you are responsible. So if the mortgage broker you are using does not provide the disclosures on time, you must make sure they do otherwise stop doing business with them, because in the end it will be your problem.

If a lender is the broker, should the lender be receiving a copy of any final documents such as final TIL, HUD, (signed), etc. if the loan doesn't close in our name? Is there any requirement for this?