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AFBD Required for Director?

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Question: 
We have a Required Service Provider that is a director and this data is properly disclosed on the GFE. Would an Affiliated Business Arrangement Disclosure also be required? My "gut" says yes but the language in our AFBD document tells me no because the AFBD document specifically states "You are NOT required to use the listed provider...".
Answer: 

The Required Provider (RP) disclosure and the Aff. Business Arrangement (AfBA) disclosure are 2 different things. Generally, you can't have a RP that is also an affiliate. The exception is attorney, credit reporting agencies and appraisers. Basically, you tell people they must use this provider (by giving the RP) and you also tell them this servicer provider is an affiliate (by giving the AfBA disclosure).

First published on BankersOnline.com 2/19/07

First published on 02/19/2007

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