We recently stopped offering credit life insurance for our loans. Our Financial Services area does not offer this product either but would offer a term life insurance policy as an alternative. If the customer comes to the loan officer and inquire about insurance, we would refer them to the Financial Services area so that they can shop for term life insurance products.
Since we are not offering the credit life insurance product anymore and our Financial Services area doesn't sell it, are we still required to provide the Federal Credit Application Insurance Disclosure to our customers? I would think that we don't need to unless a customer inquires about insurance, then we would need the disclosure to be provided to the customer.
What is your opinion on this?
Can credit life be added back to a consumer loan, if loan is maturing and the loan is being extended, whether it is secured by Real Estate or Non Real Estate? It will be added to balance.
On our consumer notes we have the credit insurance clause that the customer signs when signing the note, and on the note is also the Federal Sale of Insurance Disclosure that the customer signs if he/she decides to get the Credit Life or Disability Insurance. When printing the documents, it prints the Federal Credit Application Insurance Disclosure. All this is in our software from Arta Lending. If all this information is on the Arta Note, do we have to print and have the customer sign the disclosure also?
Where can I find a sample form of the HOEPA disclosure? I have never needed one before, but now have a closed-end junior lien with credit life and disability.
We are going to discontinue the offering and sale of credit life insurance products. Do we have to provide any type of notice or disclosure to our customers informing them of this?
A home loan application was completed on a consumer loan refinance on their dwelling and Credit Life Insurance was financed on the loan. Is the government monitoring information required or prohibited on the home loan application? (Is a refinance with cash out (ie credit life insurance) or cash out for personal use, medical, etc., subject to government monitoring information?)
What disclosures must be given if a bank is offering credit life and accident and health insurance on a consumer loan?
If you think you aren't making any high cost mortgages, you probably haven't done your homework. At some point, almost every lender either makes high cost loans or comes very close.
I am having a horrible time trying to get the concept of figuring the fee's on a loan, to verify that it's not, or is, a HOEPA loan. Is there a calculator that can do this for us? (other then the worksheet!) I have a very difficult time, trying to figure out which fees need to be where.....thank you for taking the time to read this!! And thank you in advance for the help!