I would not believe not offering credit insurance is considered discriminatory as that person can secure other policies if desired. It is less convenient. COULD it be considered discriminatory, potentially. Are SMs a protected class, not really. Should that provide you peace of mind? Not at all as I think for all practical purposes SMs are a protected class. So the answer is, it could be a risk decision. Can the interest rate be lowered to accommodate requested credit insurance? If the answer is no, the the interest and credit insurance costs need to be evaluated and perhaps the minimum loan amount needs to increase.
There are no regulatory requirements for SCRA or MLA policies or procedures. But because of the complexity and problems others have had in complying, you'd be wise to have them rather than defend why you don't.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell