[chopper]

My friend who is also a compliance person works for a mortgage company. She emailed me this question this morning and I thought maybe someone may know the answer for her.
“I do have a question regarding banks and state disclosures that you may know the answer to. We underwrite for Corr banks, they close in their name. There are state disclosures in some of these states. My wholesale manager says that because banks are not under the same restrictions as brokers and mortgage lenders they do not have to use the state disclosures. They still follow respa,tila,etc but nothing in regards to the state specific disclosures. I am waiting to hear back from the ND Dept of Financial Institutions (because the ND Division of Banking couldn’t answer this question) but I thought maybe you might know.”

Our bank does state specific disclosures. I am not sure what the wholesale manager is drawing off of to make the statement. Anyone have any input?

[rcooper]

Required disclosures can vary among states. Check to see what disclosures the state requires, when and by whom they are required to be given. Reg Z, 1026.28 discusses its effect on state law.

[Author]

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