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Affiliated Business Arrangement

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Question: 
I recently was assigned the task of reviewing all our bank's loans for documentation and compliance errors. My question is on a 2nd mortgage home equity loan do we need the affiliated business arrangement when we make the referral to our title company that is owned by a board member? We do the ABA on the refi and purchase side but I have not seen the ABA in any home equity files that I have reviewed.
Answer: 

Yes, RESPA covers loans that are secured by a first or subordinate lien on residential real property - so the ABA would be applicable.

First published on BankersOnline.com 10/09/06

First published on 10/09/2006

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