If we have a Commercial R/E loan to joint borrowers. And they apply for joint life insurance coverage. Are they considered "an individual who purchases, applies to purchase, or is solicited to purchase from you insurance products or annuities primarily for personal, family, or household purposes as defined by Consumer Protection in Sales of Insurance?

If they are applying for joint insurance in relation to the business purpose loan then I would opine they are not subject to the Consumer Sales of Insurance disclosures.

I would equate this to "key man" insurance used in commercial transactions, not covered by consumer laws.