Conflict Disclosures and ML 1022-22

March 7th, 2023

Hello to all.

Recently in one of our AML sessions, we made reference to a Conflict of Interest and/or Dual Licensure Disclosure. I have created the disclosure for our clients. It should be added to your initial disclosure package in your Loan Origination System and should be signed by your borrowers up front.

This disclosure should keep you out of trouble related to a borrower who comes back later and says, “You didn’t tell me about your dual compensation” or “You didn’t tell me my realtor was married to you”. I’m sure you get the picture. Some of the worst issues in audits are caused by misrepresentation or non-disclosure. Get ahead of this by telling your clients about dual comp or conflict relationships up front.

And if you have dual ownership, be sure you also use the standard Affiliated Business Arrangement disclosure in Book One. The test is not legal but equitable. Meaning, even if your wife owns all the processing company for example, you have equitable ownership of half and should report it.

To obtain a copy of the PDF you must be a client of ours.

Send an email to and in the subject line, in CAPS, say CONFLICT DISCLOSURE.

Admin will send the PDF to you via return e-mail.


Nelson A. Locke, Esq.

Compliance Attorney

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