Since agents may be referring their clients to Cranbrook Loans and/or Shoreline Title the AFBA disclosure must be provided to the client.
Respa states the referring party must provide the AFBA disclosure at the time of the referral. Cranbrook Loans and Shoreline Title would be providing an AFBA disclosure but that is after the fact and not compliant for the real estate brokerage.
Therefore, the agent making the referral would be required to provide the disclosure. More specifically, the regulation states the disclosure needs to be provided no later than the time of the referral.
Respa is a federal regulation and so this regulation is required in every state.
| Affiliated Business Arrangement Disclosure
https://drive.google.com/file/d/1X6BdzL5imwZIXX8zRvnhY54BT_bUHQSp/view?usp=sharing |