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#194670 - 05/27/04 02:43 PM FINANCE CHARGE OR NOT?
Anonymous
Unregistered

If bank offers a form of debt cancellation coverage such as GAP insurance, are disclosures prescribed by Reg Z required when customer does NOT purchase insurance? I know that the bank would have to have a signed disclosure when customer opts for insurance and bank does not want to count premium as finance charge, but wasn't sure about instances when customer doesn't purchase insurance.

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Lending Compliance
#194671 - 05/27/04 04:45 PM Re: FINANCE CHARGE OR NOT?
TomS Offline
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Joined: Jan 2004
Posts: 317
USA
As far as I know, there are no disclosure requirements when the customer does not purchase the insurance. One of our documents that is signed by the borrower at close does contain a statement that the borrower has elected NOT to purchase insurance, but I don't believe that statement is required by Reg Z.
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#194672 - 05/27/04 05:36 PM Re: FINANCE CHARGE OR NOT?
Anonymous
Unregistered

Thanks for the reply. Our disclosure has the same statement in it and is what caused me to ask the question.

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