Can this disclosure be signed electronically?

Yes. Under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted, electronic signatures are valid if intent, consent, attribution, and retention are satisfied. Ensure consumer-facing disclosures meet ESIGN consumer disclosure requirements.

Is notarization required for this form?

Generally no, unless state law or a related document requires notarization. Check the specific transaction and jurisdiction; some states or lenders may require notarized acknowledgments.

What happens if the consumer refuses to sign?

Record the refusal and document that the consumer was provided the disclosure. Consult counsel for transaction consequences; certain agreements may not proceed without signed acknowledgment.

How long should we keep signed disclosures?

Retain per the applicable retention timeline: at least the contract term plus three years, with longer retention for tax or HIPAA-regulated matters as required by IRC §6501(a) and 45 CFR §164.530(j).

Can I update a disclosure after it was signed?

Substantive changes require a new disclosure and fresh acknowledgment by the consumer. Minor administrative corrections can be appended with a dated amendment and signer initials.

How do I prove a digital signature’s authenticity?

Maintain the platform audit trail including IP, timestamp, signer email, and authentication method. For higher assurance, use stronger signer authentication methods or PKI digital signatures.

Electronic Signature
Templates
Miscellaneous
Miscellaneous Anti-Steering Disclosure

Miscellaneous Anti-Steering Disclosure

This template is fully customizable. Edit the text, fill out the fields, and send it for signature. Give it a try!

Miscellaneous Anti-Steering Disclosure

Recitals

WHEREAS, Provider Name: is engaged in the business of providing services described herein; and

WHEREAS, Client Name: desires to retain Provider to provide such services and to receive disclosure regarding any compensation or arrangements that could influence Provider's recommendations or referrals; and

WHEREAS, Effective Date: the parties wish to set forth both the services to be provided and the disclosures required to ensure Client is informed of any steering incentives or compensation arrangements.

Scope of Work

Description of Services

Anti‑Steering Disclosure

Provider hereby discloses to Client all known direct and indirect compensation arrangements, referral fees, commissions, and other incentives that could reasonably be expected to influence Provider's recommendations, referrals, or placement of products or services. Provider certifies that the following items accurately reflect compensation arrangements applicable to the services identified above.

Types of Compensation (check all that apply)

Commission on sale of products or services
Referral or finder fee paid by third party
Third‑party payments or soft dollars
In‑kind incentives (gifts, travel, hospitality)
Other (describe):

Compensation recipient (entity or individual):

Approximate amount or range: $ or percentage:

Conditions or circumstances under which steering may occur

Client acknowledges receipt of this disclosure and understands that the existence of compensation arrangements does not eliminate the Client's right to request alternative providers or to obtain additional information regarding any arrangement disclosed herein.

Client Acknowledgment

I acknowledge that I have read and understand the compensation disclosures set forth above and that I have had the opportunity to ask questions regarding such arrangements.

Payment Terms

Total payment for services: $

Payment schedule

Late fee or interest on past due amounts:

Term and Termination

Contract start date: and anticipated end date: .

Either party may terminate this Agreement without cause upon written notice to the other party not less than days prior to the effective termination date. Termination for material breach may be immediate if the non‑breaching party provides written notice specifying the breach and the breaching party fails to cure within a commercially reasonable period.

Confidentiality

Each party agrees that Confidential Information of the other party will be held in confidence and not disclosed to third parties except as required by law or with the prior written consent of the disclosing party. Confidential Information does not include information that is or becomes publicly available other than as a result of a breach of this Agreement, or information independently developed by the receiving party without use of the disclosing party's Confidential Information.

Duration of confidentiality obligations:

Governing Law

This Agreement shall be governed by and construed in accordance with the laws of the State of without regard to conflict of laws principles. Any action to enforce this Agreement shall be brought in the state or federal courts located in that State, and the parties submit to the jurisdiction of such courts.

Entire Agreement

This Agreement, together with any exhibits or written disclosures executed contemporaneously herewith, constitutes the entire agreement between the parties with respect to the subject matter hereof, superseding all prior or contemporaneous oral or written agreements, representations, warranties, and understandings. No amendment, modification or waiver of any provision of this Agreement shall be effective unless in writing and signed by both parties.

Each party represents and warrants that the individual signing below on its behalf is authorized to execute this Agreement and to bind the party to the terms and conditions set forth herein.

Provider Name:

By:

Date:

Client Name:

By:

Date:

Overview of the Miscellaneous Anti-Steering Disclosure

A Miscellaneous Anti-Steering Disclosure documents whether a broker, originator, or agent provided guidance, incentives, or fee arrangements that could influence a consumer to choose one product or provider over another. It clarifies relationships, compensation structures, and any material interests that might affect recommendations. The disclosure supports transparency for regulated transactions such as mortgage origination, referral arrangements, or third-party service selection, and is often appended to consumer-facing loan estimates, broker fee statements, or client advisories to document compliance and informed consent.

Why this disclosure matters

The Miscellaneous Anti-Steering Disclosure protects consumers and firms by documenting potential conflicts of interest and the basis for recommendations. It reduces regulatory risk, supports auditability, and creates a written record that can show informed consent in disputes or examinations.

Who completes and receives this disclosure

Use this disclosure when a broker, loan originator, referral partner, or advisor influences product selection and the consumer needs clarity on compensation or incentives.

Consumers seeking mortgage, lending, or financial products where broker compensation may affect recommendations.
Loan officers, mortgage brokers, and referral partners documenting fee structures and incentive arrangements.
Compliance teams and auditors reviewing disclosures for regulatory adherence and recordkeeping.

Maintain copies with transaction records and provide the consumer with a signed copy to confirm awareness and acceptance of disclosed items.

Step-by-step: completing the Anti-Steering Disclosure

Follow these steps to prepare, present, and record the disclosure so it meets consumer notice and audit requirements.

01

Prepare the form: Populate party names, transaction identifiers, and effective date.
02

Describe compensation: State exact fees, percentages, or incentive structures.
03

Disclose relationships: List affiliates, referral sources, or ownership interests.
04

Obtain signature: Have consumer sign and date; retain a signed copy.

Configuring the disclosure for digital workflows

Map fields to your eSignature platform, set required validations, and configure signer order before sending to consumers.

Field	Configuration
Disclosure Date	Required \| date mask MM/DD/YYYY
Compensation Description	Required \| multiline text
Acknowledgment Signature	Required \| signature field
Audit Trail	Auto-capture \| IP, timestamp

Typical routing and handling for the disclosure

A standard routing sequence ensures proper authoring, recipient review, signature capture, and archival for audit purposes.

Authoring: Originator prepares and pre-fills disclosure.
Delivery: Send to consumer via secure link or email.
Consumer review: Recipient reads and signs electronically or on paper.
Archival: Store signed copy in secure record repository.

Technical considerations for electronic completion

Choose an eSignature platform that supports secure delivery, required authentication, and audit-trail capture.

Authentication: Email, SMS, or KBA
File formats: PDF and DOCX
Integrations: CRM and cloud storage

Ensure the platform supports ESIGN/UETA compliance, record retention, and the integrations you use for routing and storage.

Core elements to include in a professional disclosure

A complete disclosure combines concise factual statements with clear signer acknowledgment fields to create an enforceable record and show informed consent.

Date and Identifier

A transaction date and unique identifier (loan number or file ID) link the disclosure to the underlying transaction and aid retrieval during audits.

Payor and Payee

Identify who pays compensation and who receives it, including corporate entity names and, if applicable, NAICS or license numbers to avoid ambiguity.

Compensation Details

Provide specific dollar amounts, percentages, or a clear formula for how fees are calculated so consumers understand the financial incentive structure.

Relationship Disclosures

Describe material relationships such as ownership interests, referral agreements, or affiliate connections that could reasonably influence recommendations.

Consumer Acknowledgment

A signature block with printed name, date, and a short statement indicating the consumer received and understood the disclosure.

Retention Note

A field indicating where the signed disclosure will be stored and how long it will be retained for regulatory or audit purposes.

Security and compliance items to record

Audit Trail: Capture IP, timestamp

Encryption: TLS 1.2/1.3, AES-256

Authentication: Email/SMS/KBA options

BAA Option: HIPAA BAA available

Access Controls: Role-based rights

Retention Flag: Record retention tag

Legal and operational risks of incomplete disclosures

Regulatory Penalty: Fines or enforcement

Consumer Lawsuit: Fraud or misrepresentation claims

Tax Exposure: Erroneous reporting risk

Reputational Harm: Loss of trust

Contractual Voidance: Agreement challenges

Audit Findings: Compliance failures

Common preparation mistakes to avoid

Using vague language about fees or incentives that leaves material terms open to interpretation during review or litigation.
Failing to match party names to tax or licensing records, which can trigger backup withholding or tax-reporting complications.
Not capturing a signed acknowledgment from the consumer, leaving only an unsigned template that fails evidentiary standards.
Storing disclosures in unsecured or poorly indexed locations that impede retrieval during examinations or consumer disputes.

Comparing eSignature options for completing the disclosure

Platform choice affects cost, scalability, and compliance features. The table shows typical starting prices and feature availability for common vendors.

	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	Yes, 7-day	No	No	Yes, limited	Yes, limited
Bulk Send	Yes	Yes	Yes	Yes	No
Audit Trail	Yes	Yes	Yes	Yes	Yes
Envelope Cap	No cap	100 envelopes/user/year	Varies by plan	Varies by plan	Varies by plan

Frequently asked questions and troubleshooting

Answers to common questions about completing, signing, and storing the Miscellaneous Anti-Steering Disclosure.

Need help? Contact support

Can this disclosure be signed electronically?
Yes. Under the ESIGN Act (15 U.S.C. ch. 96) and UETA where adopted, electronic signatures are valid if intent, consent, attribution, and retention are satisfied. Ensure consumer-facing disclosures meet ESIGN consumer disclosure requirements.
Is notarization required for this form?
Generally no, unless state law or a related document requires notarization. Check the specific transaction and jurisdiction; some states or lenders may require notarized acknowledgments.
What happens if the consumer refuses to sign?
Record the refusal and document that the consumer was provided the disclosure. Consult counsel for transaction consequences; certain agreements may not proceed without signed acknowledgment.
How long should we keep signed disclosures?
Retain per the applicable retention timeline: at least the contract term plus three years, with longer retention for tax or HIPAA-regulated matters as required by IRC §6501(a) and 45 CFR §164.530(j).
Can I update a disclosure after it was signed?
Substantive changes require a new disclosure and fresh acknowledgment by the consumer. Minor administrative corrections can be appended with a dated amendment and signer initials.
How do I prove a digital signature’s authenticity?
Maintain the platform audit trail including IP, timestamp, signer email, and authentication method. For higher assurance, use stronger signer authentication methods or PKI digital signatures.

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