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Finance Anti-Steering Document

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FINANCE ANTI-STEERING AGREEMENT

Parties and Effective Date

Effective Date: . This Finance Anti-Steering Agreement (Agreement) is entered into between the Finance Provider identified above and the Client identified above (each a Party and collectively the Parties) to set forth covenants, disclosures, and remedies related to the direction or recommendation of financing products, terms, or payment methods.

Provider Contact & Registration

Recitals and Definitions

Recitals: The Provider offers various financing products, including but not limited to secured loans, unsecured loans, lease-to-own arrangements, and merchant financing. The Client seeks financing and relies upon the Provider for information and recommendations. For purposes of this Agreement, "Steering" means any conduct by the Provider that intentionally directs the Client to select a financing product or payment network that is not reasonably in the Client's economic interest, where the direction is materially motivated by Provider compensation or other non-client-aligned incentives.

Anti-Steering Covenants

Provider covenants that, in connection with marketing, quoting, recommending, or originating any financing product for the Client, Provider shall:

  1. Present materially accurate and complete comparisons of reasonably available financing alternatives based on factors that are reasonably likely to be significant to the Client, including but not limited to total cost to the Client, periodic payment, term, fees, and prepayment penalties;
  2. Not direct, recommend, or incentivize the Client to choose a higher-cost product over a lower-cost product unless Provider documents a good-faith determination that the higher-cost product is reasonably necessary to accomplish an objective that is demonstrably in the Client's best interest;
  3. Disclose in writing any direct or indirect compensation, fee differentials, rebates, or referral payments from third parties that would reasonably be expected to influence Provider's recommendation for the Client's financing selection.

Compensation Disclosure

Provider hereby discloses the general method of compensation applicable to the transaction(s) with Client. Compensation shall be calculated as follows: Basis of compensation: ; Amount or rate (if percentage): ; Estimated dollar amount to Client for the presented product(s): .

Provider shall provide, upon Client request and prior to execution of financing documents, a written itemization of all compensation, credits, referral fees, and direct or indirect payments associated with each financing alternative materially presented to the Client.

Client Acknowledgment and Election

By initialing and signing below, Client acknowledges receipt of the above disclosure and acknowledges that Provider has explained available alternatives in a manner the Client understands. Client further acknowledges that Provider has disclosed any material conflicts of interest and the likely impact of Provider compensation on the recommendations made.

Client Election: I elect to proceed with the financing product described to me as: . Client understands that this Election does not waive Client's rights to review written financing documents or to rescind any transaction if permitted by law or contract.

Representations, Indemnity and Remedies

Provider represents that the foregoing disclosures are true and complete to the best of Provider's knowledge. Provider agrees to indemnify and hold harmless Client from any third-party claims arising from Provider's breach of the covenants herein, except where such claims arise from Client's own material misrepresentations.

In the event of a material breach of this Agreement by Provider, Client may seek remedies including, but not limited to, actual damages, equitable relief (including injunctive relief), and reasonable attorneys' fees. The Parties agree that, where appropriate and enforceable, liquidated damages may be set at: , which the Parties acknowledge is a reasonable estimate of anticipated harm and not a penalty.

Conflicts of Interest

Provider shall identify any material conflicts of interest that could affect independence of recommendation, including ownership interests in third-party financing sources or material referral arrangements. Where a material conflict exists, Provider shall (a) disclose the conflict in writing, (b) document the factual basis for any recommendation that may be affected by the conflict, and (c) obtain a written acknowledgment from Client prior to consummation of the transaction.

Notices

All notices required or permitted by this Agreement shall be delivered to the addresses provided above and shall be deemed received (a) upon personal delivery, (b) on the date of electronic delivery if such delivery is acknowledged by the recipient, or (c) three (3) business days after deposit with a nationally recognized overnight courier.

Governing Law and Miscellaneous

This Agreement shall be governed by and construed in accordance with the laws of the state of , without regard to choice of law principles. If any provision is held unenforceable, the remaining provisions shall remain in full force and effect.

Acknowledgments (Checkboxes)

I acknowledge receipt of Provider's compensation disclosure and explanations of available alternatives.

Provider represents that there are no additional undisclosed incentives that would materially influence the recommendation.

Finance Provider Printed Name:

By:

Date:

Client Printed Name:

By:

Date:

Enter text

What the Finance Anti-Steering Document Is

A Finance Anti-Steering Document records the consumer-facing disclosure of financing options and any dealer or broker compensation that could influence a purchaser’s choice of credit. It documents alternative loan offers, annual percentage rates, fees, and whether the seller or intermediary received incentives to favor one finance source. The form creates an auditable record for compliance, consumer review, and internal controls, and it is commonly used at the point of sale in auto finance and other consumer lending transactions.

Why this document matters for compliance and transparency

The Finance Anti-Steering Document promotes clear, consistent disclosure of financing options, reduces legal and reputational risk, and creates an evidence trail that regulators and auditors can review. It helps demonstrate that consumers were informed and that dealer or broker practices did not improperly influence financing selection.

Why this document matters for compliance and transparency

Who typically completes and relies on this document

The form is useful when a consumer is choosing financing and when an organization needs an auditable record of how financing alternatives were presented.

  • Auto dealers and finance managers who present loan or lease options to consumers at purchase and must document alternatives and compensation disclosures.
  • Consumer finance departments at banks and captives that must track referred business and ensure regulatory compliance.
  • Compliance and audit teams that use the document as evidence during internal reviews and external examinations.

Essential sections to include in a professional form

A complete Finance Anti-Steering Document combines consumer disclosures, option comparisons, compensation details, certification statements, signature blocks, and recordkeeping instructions.

Consumer Disclosure

Clear language that explains the consumer’s right to choose among financing options and whether any dealer or broker compensation could affect the referral or recommendation.

Financing Comparison

A side-by-side table of offered credit options showing lender name, APR, term, monthly payment, total finance charge, and any prepayment penalties or fees for direct comparison.

Compensation Details

Explicit statement of dealer or broker commissions, reserve amounts, yield spread premiums, or third-party incentives tied to a particular finance source or product.

Certification Statement

Signature-ready declaration from the dealer/representative certifying that the consumer received and reviewed alternatives and that information shown is accurate to the best of their knowledge.

Signature Block

Fields for consumer signature, printed name, date, and seller signatory—plus optional witness or notary blocks if required by state or institutional policy.

Record Instructions

Guidance on retention period, where to file the executed form, and how to provide a consumer copy, including electronic delivery and archive procedures.

Required data elements to capture

Borrower Name: Full legal name
Lender/Finance Source: Named lender or creditor
Dealer Name: Selling dealer or broker
APR / Rate: Annual percentage rate
Loan Term: Months or years
Signature Block: Consumer signature and date

Step-by-step: completing the Finance Anti-Steering Document

Follow these steps to ensure the form is complete, consistent, and retained according to policy.

  • 01
    Step 1: Enter consumer and transaction details accurately.
  • 02
    Step 2: List all offered finance options with APRs and terms.
  • 03
    Step 3: Disclose any dealer or broker compensation tied to options.
  • 04
    Step 4: Obtain consumer signature and provide a copy.

Recommended online workflow settings

Configure digital workflows to capture data, require consent, and preserve an audit trail for each signed form.

Field Configuration
Authentication Level Email link with optional SMS code
Signature Type Typed or drawn e-signature allowed
Delivery Method Email copy and downloadable PDF
Retention Setting Secure archive with access controls

What happens after the form is executed

Understand the routing and storage steps so parties know where to send and how long to retain the executed document.

  • Provide Consumer Copy: Deliver signed copy at sale; retain electronic copy.
  • File with Dealer Records: Attach to sales file and loan application.
  • Send to Lender: Include with funding package or disclosure set.
  • Preserve Audit Trail: Store signature metadata and access logs.

Technical and platform considerations for e‑delivery and signing

Ensure the chosen system can export signed PDFs with certificate of completion and retains records according to your retention policy.

  • Integrations: Salesforce, NetSuite, Microsoft 365
  • File Formats: PDF and DOCX supported
  • Security: TLS in transit, AES-256 at rest

Timing: when the document should be presented and retained

Timing affects enforceability and consumer understanding; present the document at or before financing selection and retain executed copies per policy.

Presentation Timing:

Provide at time of finance selection or before document signing.

Consumer Review Period:

Allow sufficient time for review before financing commitment.

Retention Start:

Retention begins on the execution date of the form.

Response to Disputes:

Acknowledge consumer disputes within 30 days where policy requires.

Record Availability:

Maintain accessible copies for audits and exams.

Common preparation and execution pitfalls

  • Incomplete comparisons that omit key costs or fees, which can mislead consumers and increase regulatory exposure.
  • Using inconsistent APRs or payment numbers across disclosures, leading to consumer confusion and reconciliation failures.
  • Failing to record or disclose dealer compensation tied to a particular lender, risking compliance violations under consumer protection rules.
  • Not preserving an audit trail or proof of delivery, which complicates response to disputes or regulatory requests.

Potential consequences of errors or omissions

Regulatory Fines: Civil enforcement actions
Contract Rescission: Consumer may rescind deal
Reputational Harm: Loss of consumer trust
Repayment Costs: Refunds or adjustments
Increased Audits: Regulator scrutiny
Civil Litigation: Potential class actions

eSignature vendor comparison for executing this document

Below is a concise vendor comparison for common capability and pricing criteria; signNow is listed first per platform options.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies by plan Varies by plan Varies by plan Varies by plan
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No envelope cap 100 envelopes/user/year Varies by plan Varies by plan Varies by plan

Frequently asked questions and troubleshooting

Answers to common legal, execution, and retention questions about the Finance Anti-Steering Document.


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