06/01/2003
Predatory lending has been front and center for several years - and it is staying there.
05/19/2003
Our credit life provider is offering bonuses during a special promotional period to our lenders for selling credit life based on the volume of premiums. Some of these policies are for mortgages (RESPA). Is this a violation of Section 8 of RESPA? If so, would it make a difference if they excluded the amount of the premiums from the real estate loans to calculate the bonus?
04/07/2003
In the regulation, "Consumer Protection in Sales of Insurance", the coverage applies to insurance offered or sold to a consumer. I initially interpreted the text as not covering business transactions, but now I'm not sure. For example, if you have a loan to an individual for business purposes, but credit insurance is solicited or sold, does the regulation apply? If you have a loan to a corporation and an officer purchases credit life, does the regulation apply?
02/17/2003
Can we require that a borrower obtain credit life or disability insurance as a condition of a loan subject to TILA? If we can, I assume we must include the premium in the finance charge and adjust our TILA disclosure so that it does not state "Credit insurance is not required."
12/01/2002
Question: I know that we need to get the customer's signature if we sell voluntary credit life insurance to avoid including the premium in the finance charge.
11/11/2002
Where can I find information about what fees are included in a section 32 and the amount of fees allowed?
07/01/2002
I have a question about the rules on bank solicitation or sale of insurance products. From what I understand, there have to be two disclosures. One disclosure when a customer APPLIES for a loan and the other disclosure if the customer's application is approved and they decide to purchase credit life. Both disclosures have to be given orally and in writing. Do we have to get the customer to sign a document stating that they have been given the disclosures?
07/01/2002
Is there a simplified summary of the current, pending HOEPA changes/regulations, pertinent to a mortgage nondepository lender?
01/07/2002
Can you issue credit life and/or disability when renewing or doing a change in terms on an existing closed end consumer loan?
12/03/2001
If we do not offer or solicit credit life insurance for a credit card until AFTER the customer has been notified (in writing) of credit approval, is the "credit disclosure" still required at time of application? (I would interpret this as a nonpending application). Or would the "insurance disclosure" be the only required disclosure (if a purchase occurs.)Again, the consumer isn't presented with any solicitation until after the credit has been approved, and the consumer has ben notified of credit approval.