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Do I Have to Do an Anti-Steering Loan Option Disclosure Sample if I Work With Only One Non-QM Lender?

Do I Have to Do an Anti-Steering Loan Option Disclosure Sample if I Work With Only One Non-QM Lender?

As a mortgage broker, it is important to understand the requirements for anti-steering loan option disclosures. Even if you work with only one Non-QM lender, you may still be required to provide an anti-steering loan option disclosure sample to your clients. One of the requirements for anti-steering loan option disclosures is that you must clearly explain to your clients that different loan products have different costs, terms, and features. Additionally, the borrower should be provided with an example of a non-QM loan product alongside any QM loan products being offered. This allows your borrowers to make an informed decision between the different loan products. Here is a list of things to consider when presenting different options:
  • Clearly explain to clients that different loan products have different costs, terms and features.
  • Provide an example of a non-QM loan product alongside any QM loan products being offered.
  • Explain the benefits and drawbacks of each type of loan option.
  • Describe the application process for each kind of loan product available.
  • Highlight potential risks associated with non-QM loans for borrowers who may not be familiar with them.
  • Present options in a clear and concise manner so that customers can make informed decisions about their mortgage financing needs.
As mentioned above, you’ll want to ensure that your clients are aware of any potential risks associated with non-QM loans. This includes potentially higher interest rates, stricter credit requirements, and generally less favorable terms and conditions than QM loans. You should be prepared to answer any questions your borrowers may have about the different loan products being offered. By doing so, you can ensure that your clients are making a well-informed decision about their mortgage loan. It is also important that you explain to your clients that they are not obligated to take a non-QM loan product, even if it may be more suitable for their needs and financial situation. This must be done in order to avoid any potential accusations of steering customers away from QM loans and towards non-QM loans. The anti-steering rule, which is part of the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA), requires mortgage brokers to provide borrowers with a list of loan options from various lenders, not just the one the broker works with. This helps to ensure that borrowers have access to a variety of loan products and can make an informed decision. However, there are exceptions to this rule, such as when a broker works with only one lender that offers a specific type of loan product. In this case, the broker may not be required to provide a list of loan options from other lenders, but they still must provide an anti-steering loan option disclosure sample to the borrower. This disclosure explains to the borrower that they have the right to shop around and compare loan options from other lenders, even if the broker only works with one lender. The disclosure should also include information on how to find other lenders and loan options. As a mortgage broker working with one non-QM lender, you may not have to provide a list of loan options from other lenders, but you still need to provide an anti-steering loan option disclosure to your clients. It is important to ensure that you are following all relevant regulations and providing your clients with the information they need to make an informed decision about their mortgage.

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Texas SML - Mortgage Company License - CONSUMERS WISHING TO FILE A COMPLAINT AGAINST A COMPANY OR A RESIDENTIAL MORTGAGE LOAN ORIGINATOR SHOULD COMPLETE AND SEND A COMPLAINT FORM TO THE TEXAS DEPARTMENT OF SAVINGS AND MORTGAGE LENDING, 2601 NORTH LAMAR, SUITE 201, AUSTIN, TEXAS 78705. COMPLAINT FORMS AND INSTRUCTIONS MAY BE OBTAINED FROM THE DEPARTMENT’S WEBSITE AT WWW.SML.TEXAS.GOV. A TOLL-FREE CONSUMER HOTLINE IS AVAILABLE AT 1-877-276-5550.

THE DEPARTMENT MAINTAINS A RECOVERY FUND TO MAKE PAYMENTS OF CERTAIN ACTUAL OUT OF POCKET DAMAGES SUSTAINED BY BORROWERS CAUSED BY ACTS OF LICENSED RESIDENTIAL MORTGAGE LOAN ORIGINATORS. A WRITTEN APPLICATION FOR REIMBURSEMENT FROM THE RECOVERY FUND MUST BE FILED WITH AND INVESTIGATED BY THE DEPARTMENT PRIOR TO THE PAYMENT OF A CLAIM. FOR MORE INFORMATION ABOUT THE RECOVERY FUND, PLEASE CONSULT THE DEPARTMENT’S WEBSITE AT WWW.SML.TEXAS.GOV.

Regulated by the Illinois Department of Financial & Professional Regulation - Illinois Residential Mortgage License # MB.6761251 100 W. Randolph, 9th Floor, Chicago IL 60601 - 1(888) 473-4858 - https://idfpr.illinois.gov

State of Illinois community reinvestment notice - The Department of Financial and Professional Regulation (Department) evaluates our performances in meeting the financial services needs of this community, including the needs of low-income to moderate-income households. The Department takes this evaluation into account when deciding on certain applications submitted by us for approval by the Department. Your involvement is encouraged. You may obtain a copy of our evaluation. You may also submit signed, written comments about our performance in meeting community financial services needs to the Department.

Arizona Mortgage Banker License # 1004354

Delaware Lender License # 027932