Anti-Steering Loan Options Disclosure

Summary

This model anti-steering/loan options disclosure template is prepared for use by financial institutions, specialty finance companies, and mortgage lenders in connection with transactions where a mortgage loan originator (MLO) is compensated by someone other than their employer or the consumer. This template includes practical guidance and optional clauses. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) prohibits MLOs from getting paid on the terms of the mortgages they sell, including broker transactions where the lender is paying a mortgage broker compensation. This template is prepared to comply with applicable provisions of Regulation Z (12 C.F.R. § 1026.36(e)), which implements the federal Truth-in-Lending Act (15 U.S.C. §§ 1601, et seq.). For a full listing of key materials necessary to develop consumer-related bank policies and procedures central to regulated depository institution operations, see Developing Bank Policies and Procedures Resource Kit. For information on TILA, see Truth-in-Lending Disclosures and Related Considerations. For information on Dodd-Frank Requirements, including the ability-to-repay rule, qualified mortgage (QM) standard, and enforcement by the Consumer Financial Protection Bureau (CFPB), see Ability to Repay Rule and Qualified Mortgage Standard.