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Legal Anti-Steering Form

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LEGAL ANTI-STEERING FORM

This Anti-Steering Form is entered into as of by and between Client Name: and Broker/Firm Name: (together, the Parties).

RECITALS

WHEREAS, Client has engaged Broker to provide advisory and placement services in connection with the transaction described as: ; and

WHEREAS, Broker receives or may receive compensation, fees, commissions or other economic benefits from multiple sources in connection with such transaction; and

WHEREAS, Client requires written assurance that Broker will not steer Client to any particular product, lender, or counterparty on the basis of Broker's compensation arrangements except as expressly disclosed and consented to in this Form.

NOW, THEREFORE

In consideration of the mutual covenants set forth below, the Parties agree as follows:

1. DEFINITIONS

For purposes of this Form, "Compensation" means any fee, commission, rebate, override, bonus, or other monetary or non-monetary benefit paid or payable to Broker by Client, any lender, issuer, or third party in connection with the transaction.

2. BROKER ANTI-STEERING COVENANT

Broker affirms that it will not, directly or indirectly, steer, recommend, or otherwise direct Client to select a particular lender, product, or counterparty for reasons that are primarily motivated by Broker's Compensation unless such Compensation and the basis for any recommendation are fully disclosed in writing and consented to by Client as set forth in Section 3 below. Broker shall make recommendations based on Client's stated financial objectives, needs, and best interests.

3. COMPENSATION DISCLOSURE

Broker discloses the following categories of potential Compensation in connection with the transaction. Client acknowledges receipt of the disclosure of such categories and amounts as indicated below and agrees that the presence of such Compensation shall not, alone, constitute improper steering if fully disclosed and reasonably related to market terms.




4. CONFLICTS OF INTEREST

Broker shall disclose any material conflicts of interest that reasonably could affect Broker's independence of judgment. Material conflicts include, without limitation, ownership interests in a lender, ongoing referral arrangements that provide economic benefit tied to placement, or contingent bonuses tied to volume of business placed with a particular counterparty.

5. CLIENT ACKNOWLEDGEMENTS

Client acknowledges receipt of the disclosures in this Form, has had an opportunity to ask questions, and understands the sources and estimated amounts of Compensation to the extent known. Client further acknowledges that Client may at any time request additional written information regarding Broker's Compensation and the basis for any recommendation.

6. REPRESENTATIONS AND WARRANTIES

Each Party represents and warrants that it has full authority to enter into this Form and that the individual signing on its behalf has been duly authorized. Broker represents that to the best of its knowledge the disclosures in this Form are true and complete as of the Effective Date.

7. REMEDIES; INDEMNIFICATION

In the event Broker materially breaches the Anti-Steering Covenant, Client may pursue all available legal and equitable remedies, including but not limited to damages and injunctive relief. Broker shall indemnify, defend, and hold Client harmless from any losses, liabilities, costs or expenses (including reasonable attorneys' fees) arising from Broker's breach of this Form or from inaccurate or incomplete disclosures required herein.

8. TERM AND TERMINATION

This Form is effective as of the Effective Date and shall remain in effect for the duration of Broker's engagement in connection with the specified transaction, unless earlier terminated in writing by mutual agreement of the Parties. Termination of this Form shall not relieve any Party of obligations that accrued prior to termination.

9. NOTICES

All notices required or permitted by this Form shall be in writing and delivered to the addresses below by hand, nationally recognized overnight courier, or certified mail, return receipt requested, and shall be effective upon receipt.

10. GOVERNING LAW; VENUE

This Form shall be governed by and construed in accordance with the laws of the State of , without regard to its conflicts of law principles. The Parties submit to exclusive jurisdiction in the state and federal courts located in that State for any dispute arising under this Form.

11. ENTIRE AGREEMENT; SEVERABILITY

This Form constitutes the entire agreement between the Parties with respect to the Anti-Steering obligations described herein and supersedes all prior and contemporaneous oral or written agreements, understandings, and communications concerning the subject matter hereof. If any provision of this Form is held to be invalid or unenforceable, such provision shall be reformed only to the extent necessary to make it enforceable, and the remaining provisions shall remain in full force and effect.

12. AMENDMENTS; WAIVER; COUNTERPARTS

Any amendment or modification to this Form must be in writing and signed by both Parties. No waiver of any breach shall constitute a waiver of any other breach. This Form may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one instrument. Signatures transmitted by facsimile or electronic image shall be binding.

Client

Printed Name:

By:

Date:

Broker/Firm

Printed Name:

By:

Date:

Enter text✕

What the Legal Anti-Steering Form Is and why it matters

A Legal Anti-Steering Form is a written disclosure used in commercial or consumer transactions to document that a party (often an agent, broker, or advisor) will not steer the counterparty toward a particular product, provider, or offer in exchange for undisclosed incentives. The form clarifies compensation arrangements, confirms that alternatives were considered, and creates a record of the distributor’s or advisor’s stated guidance. In consumer finance and professional services, the disclosure helps align expectations, reduce conflicts of interest, and support regulatory compliance where rules require clear written notice of steering practices.

Why include a Legal Anti-Steering Form in your process

The form documents impartiality and compensation transparency, reduces regulatory risk, and creates an auditable record showing that parties received required disclosures before proceeding with a transaction.

Why include a Legal Anti-Steering Form in your process

Which roles typically complete or receive this form

Common users include brokers, financial advisors, compliance officers, legal counsel, and consumers or clients who receive product recommendations.

  • Brokers and agents — Use the form to disclose compensation structures and confirm no undisclosed steering occurred before a sale or referral.
  • Financial advisors — Document alternative options considered, the rationale for recommendations, and any commissions or referral fees.
  • Compliance/legal teams — Retain signed records to demonstrate adherence to disclosure rules and to support audits or regulatory inquiries.

Signed forms are evidence for internal review, regulatory examination, or dispute resolution and should be stored according to applicable retention rules.

Step-by-step: completing the Legal Anti-Steering Form

Follow these sequential steps to ensure the form is complete, accurate, and legally defensible.

  • 01
    1. Identify Parties: Enter full legal names for all parties signing the form.
  • 02
    2. Describe Relationship: Summarize the advisor role and the scope of recommendations.
  • 03
    3. Disclose Compensation: List commissions, fees, and third-party payments precisely.
  • 04
    4. Sign and Date: Each signer must sign and date; include printed names.

Configuring an online workflow for this form

Set up a clear routing and authentication workflow so each signer receives the form in the correct order and identity is verified.

Field Configuration
Signer Order Sequential or parallel routing as required
Authentication Email with SMS code or stronger KBA
Mandatory Fields Make compensation and signature fields required
Audit Trail Enable detailed timestamps and IP logging

Typical eSubmission flow for the Legal Anti-Steering Form

A standard electronic submission sequence reduces signer friction and preserves evidentiary detail.

  • Upload Document: Sender uploads final form PDF or DOCX.
  • Place Fields: Add signature, date, and text fields for each party.
  • Assign Signers: Enter signer emails and set routing order.
  • Send and Sign: Signers authenticate and complete fields; record saved.

Technical considerations for digital signing and storage

Choose a platform that supports audit trails, secure transport, and the authentication level your regulators require.

  • Transport Security: TLS 1.2/1.3 required
  • At-Rest Encryption: AES-256 encryption
  • Audit Trail: Detailed timestamps and IP logging

Ensure any selected eSignature provider can meet ESIGN/UETA legal tests and offer HIPAA BAA or other attestations if your industry requires them.

Core sections every professional Legal Anti-Steering Form should include

A complete form groups disclosure, factual context, and authentication elements to create a usable legal record.

Parties

Clear identification of all parties, including business entities, addresses, and signer roles to avoid ambiguity during enforcement.

Scope

Description of the services or advice covered by the disclosure so it ties directly to the transaction at issue.

Compensation

Itemized list of commissions, referral fees, and indirect benefits with formulas or percentage rates where applicable.

Alternatives

Short summary of materially different products, providers, or price points that were considered by the advisor.

Acknowledgment

A signed acknowledgment that the recipient received the disclosure and had the opportunity to ask questions.

Authentication

Signature, date, and any notarization or witness lines required by applicable state law or industry rules.

Supporting attachments commonly included with the disclosure

Attach documents that corroborate the disclosure and provide context for the decision recorded on the form.

Compensation Schedule

A table or exhibit showing historical or prospective payment calculations, sample math, and payer identity to substantiate the Compensation section.

Product Comparison

A concise comparison of key alternatives reviewed, including costs, fees, and salient features that influenced the recommendation.

Regulatory Notice

Any statutorily required consumer notice or acknowledgement language that must accompany the disclosure in your jurisdiction or industry.

Client Questions Log

A record of client questions and responses during the recommendation process, useful in disputes or compliance reviews.

Potential penalties and legal risks if the form is incorrect or missing

Regulatory Fines: Enforcement fines and corrective orders by state or federal regulators
Contract Voidance: Errors could render disclosures ineffective and jeopardize contract enforceability
Reputational Harm: Public or customer complaints may damage trust and business standing
Consumer Remedies: Risk of rescission or restitution claims by consumers
Audit Findings: Negative audit results leading to remediation costs
Legal Costs: Higher attorney and litigation expenses to defend disputes

Common preparation mistakes to avoid

  • Leaving compensation fields vague or incomplete, which undermines the purpose of an anti-steering disclosure and invites disputes.
  • Using inconsistent party names or abbreviations that make it difficult to match the disclosure to contracts or payment records.
  • Failing to secure clear, dated signatures or relying on unsigned emails without meeting ESIGN/UETA intent and consent tests.
  • Neglecting retention or audit-trail capture, eliminating evidence needed for compliance reviews or dispute resolution.

Security and compliance controls to require for electronic execution

Transport: TLS 1.2/1.3
At-Rest: AES-256 encryption
Certifications: SOC 2 Type II
Regulatory: ESIGN and UETA compliance
Healthcare: HIPAA BAA available
FDA / Audit: 21 CFR Part 11 support

eSignature vendor comparison for signing and storing the form

This comparison summarizes core pricing and capability criteria across common eSignature vendors. signNow appears first per platform labeling guidance.

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 cap 100 envelopes/user/year Varies Varies Varies

FAQs and troubleshooting for the Legal Anti-Steering Form

Answers to frequent questions about validity, eSignature use, retention, and state considerations when completing this disclosure.


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