I happen to have a file on my desk right now wherein the selling broker is affiliated with a huge real estate agency.  This real estate agency owns the title company that is doing the closing on behalf of the buyer.  HOWEVER, there is no disclosure form relating to the AfBA.

Well, as it turns out the actual title agent doing the closing has a different name and their web-site says that are a "licensee" of the larger entity.  So, does that distinction mean that they are not considered an "affiliated entity"?  And, then, does that mean that they can cirumvent the 3% cap?  And, too, does that mean that are not required to offer, as part of the contract of sale, the ABA disclosure form?