Now that we are into the 5th month of Consumer Protection of Insurance Sales, I'm starting to have more discussions on providing disclosures. Here are my current questions:

1. A bank has a partial ownership in a title company with other banks. On some real estate secured loans, the bank purchases lender title insurance, but does not charge the customer. (These are not purchases, so there is no owners policy.) There would be no requirement for an AfBA, but wouldn't you need insurance disclosures? (The Bank receives dividends representing profits of the title company at the end of the year.)

2. A Bank rents an office to a non-affiliated insurance company. There is very nice signage identifying it, and it is across the lobby from FDIC activities. The Bank receives only rental income from the insurance company. Advertising literature for the insurance co indicates "XYZ Insurance Company at 123 Bank". (Similar to identifying an office building) There are no referral fees paid to employees by the insurance company. The Bank DOES advertise the insurance company when they place a telephone call on hold. Any disclosure issues here that anyone can think of?