AfBA disclosures treated as a paperwork exercise delivered at the wrong time or drafted to disguise the fees charged or who the actual owners are.” “While I think the AfBA disclosure is the easiest condition of the safe harbor to satisfy, we rarely see compliant AfBA disclosure content and oftentimes disclosures are not provided in a timely manner,” she said. There are exit strategies that can be effective, but these are generally untested for RESPA compliance.” Cheatham, Sterbcow and Salzano go on to discuss how builder-lender-title JVs, vertically integrated builders and “one-stop shops” may impact the housing supply. For more stories on housing supply, visit our sister publication The Title Report's Housing Inventory & Attainability Watch library.