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ANTI-STEERING LOAN OPTIONS
DISCLOSURE INFORMATION TOOL
PSBank Wholesale Lending Division
The Loan Originator Compensation Rules offer brokers protection from steering violations (Safe Harbor) by providing
consumers with a choice of loan options. This Safe Harbor is available on transactions where the Loan Originator
receives lender paid compensation. In order to comply with this provision, a written Loan Options Disclosure must be
provided to the borrower(s) on all Lender Paid Compensation transactions. Prairie Sun Bank (“PS Bank”) provides a
Loan Options Disclosure section on our Mortgage Broker Fee Agreement (MBFA), or if preferable, a separate Loan
Options Disclosure form is available on our website in those instances where a state specific MBFA is utilized. An
alternate loan options form may be used provided it meets the requirements as outlined below. Attention to detail on
this disclosure is critical as inaccurate and incomplete forms will render the loan ineligible to PS Bank.
How to Complete the Loan Options Table
To qualify for the Safe Harbor protection, the borrower must be presented with loan options for each type of loan (as
defined at a minimum by fixed rate or variable rate) in which they expressed an interest and include the following:
1) Loan with the lowest interest rate
2) Loan with the lowest interest rate without risky features, defined as a loan without negative amortization, a
prepayment penalty, interest-only payments, a balloon payment in the first 7 years of the loan, a
demand feature, shared equity, or shared appreciation. Risky features do not include the payment of
discount points or variable rates
3) Loan with lowest total dollar amount for origination points or fees & discount
When presenting the loan options, the loan originator need only evaluate those loan offers that are available from
creditors with whom the company regularly does business. A mortgage broker regularly does business with a creditor if:
 There is a written agreement;
 The creditor has extended credit to one or more consumers during the current or previous calendar
month based on an application submitted by the mortgage broker; or
 The creditor has funded 25 or more transactions for the mortgage broker in the past 12 calendar months.
It is important to review the information provided on the form to ensure it makes logical sense and accurately reflects the
information that was presented to the borrower. If the type of transaction changes, loan choices for that new type will also
need to be presented to the borrower and reflected on a new loan options form. All loan options disclosures must be
signed and dated by all borrowers a minimum of 1 day prior to closing (defined as the date the Note is signed and security
instrument has been acknowledged).
Type of Transaction:
#1
#2
#3
#4
30 year fixed rate
Loan Option with lowest interest rate.
Loan with the lowest interest rate without risky
features.
Loan with lowest total dollar amount for
origination points or fees and discount points.
You are applying for a loan with the following
terms.
Anti-Steering Loan Options Disc Info Tool UG-010 rev. 02
Page 1 of 3
4.00%
Total Origination
Points/Fees & Discount
Points
$2,500
4.25%
$3,000
4.5%
$0
Interest Rate
Total Origination
Points/Fees & Discount
Points
4.25%
$3,000
Interest Rate
11/7/2012
ANTI-STEERING LOAN OPTIONS
DISCLOSURE INFORMATION TOOL
PSBank Wholesale Lending Division
Type of Transaction: Defined at a minimum by fixed interest rate or variable interest rate.
Interest Rate: Rate offered to borrower for type of loan; if an ARM and the initial rate is fixed for a minimum of 5 years,
the rate disclosed will be the rate in effect at the time of closing. If fixed for less than 5 years, the rate will be the fully
indexed rate that would be in effect at the time of closing.
Total Origination Points or fees & discount points: Defined as ’Your Adjusted Origination Charges’ from the Good
Faith Estimate (Block A) that would be presented to the borrower should they select that particular loan. The amount
disclosed in this section reflects the anticipated origination and discount charges prior to any seller credits, if applicable.
Intheexampleabove:
#1: Reflects the lowest interest rate available to the borrower at 4.0% for a 30 year fixed rate and the corresponding
settlement cost of $2,500 from Block A of the GFE. It is possible that this loan type includes a prepayment penalty or
interest only payments or other risky features.
#2: Reflects the lowest interest rate available to the borrower at 4.25% for a 30 year fixed rate loan without risky features
and the corresponding origination points or fees and discount points of $3,000.
#3: Reflects the loan with the lowest total origination points or fees and discount points of $0 for a 30 year fixed rate loan
at a rate of 4.5%. A higher rate is likely reflected for this option due to higher premium pricing credit that offsets
origination points or fees and discount points.
#4: Reflects that the borrower selected an interest rate of 4.25% for total origination points or fees and discount fees of
$3,000. The Loan Options/Anti-Steering Disclosure is provided at the time that loan options are discussed and there is no
requirement that the loan be locked at the time the options are provided. In addition, there is no requirement that a new
Anti-Steering Loan Options disclosure be updated when interest rates change or a new GFE is provided due to a valid
change of circumstance.
Anti-Steering Loan Options Disc Info Tool UG-010 rev. 02
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11/7/2012
ANTI-STEERING LOAN OPTIONS
DISCLOSURE INFORMATION TOOL
Note: If the loan options presented have no risky features, the rate and total origination points or fees and
discount in #1 and #2 may be the same.
Reviewing the Loan Options/Anti-Steering Disclosure
Type of Transaction (check one)
Fixed Rate
Adjustable Rate
Loan with the lowest Interest Rate.
Interest Rate
Type must be
complete and
match type of
loan closed
Option with
Lowest Rate
must show
3 Options
LoanAllwith
the low est Interest Rate w ithout risky features such as neg ative
lowest interest
must be prep ayment penalty, interest-only payments, a balloon
amortization,
rate of all
completed
(NA fir st 7 years of the life of the loan, a demand feature,
options
payment in the
or blank is not
on.
shared
appreciate
acceptable)
Loan with the low est total dollar amount for origination points or fees and
discount points.
Reflects Interest Rate and adjusted origination charges for
which the borrower applied
You are applying for a loan with the following terms.
%
$
%
Interest Rate
%
Borrower:
Co-Borrower:
Signatrue:Form must be
Signature:
Date:
%
Total Origination
Points/Fees & Discount
Points
$
signed and
dated by all
borrowers at
least 1 day prior
to closing
Option with
Lowest Total
dollar amount
must show
lowest $ of all
options
$
Total Origination
Points/Fees & Discount
Points
$
GFE Block A
Date:
Red Flags
All 3 loan options have same terms
Option with the lowest interest rate is the same as the
Option with the lowest points
Form contains blanks or N/A
Transaction type does not match final loan type
Anti-Steering Loan Options Disc Info Tool UG-010 rev. 02
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Resolution
Correct form to show accurate loan options available to
borrower from various creditors OR provide supporting
documentation, i.e. rate sheets., explanations, etc.
from originator
Correct form to show accurate loan options available to
borrower from various creditors OR provide supporting
documentation, i.e. rate sheets, explanations, etc. from
originator
Obtain updated disclosure with completed loan options
Obtain completed disclosure for transaction type;
borrower(s) must sign & date one day prior to closing
11/7/2012