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#1853107 - 09/17/13 09:10 PM I'm not going crazy... or am I?
Chuck Finley Offline
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Chuck Finley
Joined: Jun 2010
Posts: 68
If we sell credit life and disability on loans, but it is not a condition of getting the loan, it should not be included on the TIL... correct?

The Finance Charge field and the Amount Financed should always equal the total of payments on a TIL correct?

I noticed on one loan that the Amount Financed and the Finance Charge did not equal the Total of Payments box. The difference was the credit life. I am correct in saying that this is wrong?


It’s one of those days.... thanks in advance. I needed to bounce this off someone.

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Lending Compliance
#1853156 - 09/18/13 01:54 AM Re: I'm not going crazy... or am I? Chuck Finley
Truffle Royale Offline

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You are correct on all counts.

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#1854492 - 09/23/13 02:44 PM Re: I'm not going crazy... or am I? Chuck Finley
Chuck Finley Offline
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Chuck Finley
Joined: Jun 2010
Posts: 68
To bring this topic back up. Is it required that we do not disclose it on the til? I know it would increase our APR, but is there another reason we would want to exclude it?

(1) Voluntary credit insurance premiums. Premiums for credit life, accident, health, or loss-of-income insurance may be excluded from the finance charge if the following conditions are met:

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#1854514 - 09/23/13 03:32 PM Re: I'm not going crazy... or am I? Chuck Finley
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
but is there another reason we would want to exclude it?

Including it in the finance charge for the average consumer loan would most likely cause you to exceed your state's Usury rate.

The Reg. allows voluntary credit insurance to be excluded from the finance charges if properly disclosed. I'm not sure why anyone would not want to take advantage of this exclusion.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1854533 - 09/23/13 03:51 PM Re: I'm not going crazy... or am I? Dan Persfull
Chuck Finley Offline
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Chuck Finley
Joined: Jun 2010
Posts: 68
Thanks Dan!

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