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?
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