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Broker Provide Copy of CHARM Booklet?

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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?

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

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