Skip to content

Broker Provide Copy of CHARM Booklet?

Answered by: 

Question: 
Can a broker provide the borrower a copy of the CHARM booklet? If so, does the lender have any responsibility to ensure it was provided timely?
Answer: 

The CHARM booklet is part of the disclosure required under 1029.19(b) which includes both the booklet and the early ARM disclosure.

You need to read comments 2 and 3 to 1026.19(b) Certain Variable-Rate Transactions

If the broker is a legal agent (as determined by applicable law) or any other third party that is not an “intermediary agent or broker.” then they would have to deliver both.

If they are not, then the responsibility for delivery is the creditor's and I am not sure why you would want to outsource that function. How would you either control it or verify?

First published on 02/23/2020

Filed under: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics