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#2103647 - 10/19/16 02:24 PM Insurance Disclosure for Credit Application - HELP
Irishguy Offline
Platinum Poster
Irishguy
Joined: Aug 2008
Posts: 589
Kentucky
I'm in the process of completing an indirect lending audit. I've noticed that the dealers are not obtaining the Insurance Disclosure for Credit Application. The dealers sell GAP, service contracts and VSI. No credit life or AH is sold on these loans. The dealer closes the contract/loan and then we purchase the paper and fund the loan.

Here is my question, is the Insurance Disclosure for Credit Application required for:

1. GAP (I understand that it might depend upon the coverage - GAP Waiver vs GAP Insurance)
2. VSI (We do require VSI but give the borrower the opportunity to find their own....the VSI fee is offered by the dealer but the fee is retained by the bank).
3. Service/Maintenance Agreements

While I would love opinions, if you can provide a regulatory site that would be even better.

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Lending Compliance
#2103890 - 10/20/16 04:13 PM Re: Insurance Disclosure for Credit Application - HELP Irishguy
Irishguy Offline
Platinum Poster
Irishguy
Joined: Aug 2008
Posts: 589
Kentucky
Bump - Anyone?

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#2104120 - 10/21/16 06:12 PM Re: Insurance Disclosure for Credit Application - HELP Irishguy
Irishguy Offline
Platinum Poster
Irishguy
Joined: Aug 2008
Posts: 589
Kentucky
Anyone???

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#2104136 - 10/21/16 07:06 PM Re: Insurance Disclosure for Credit Application - HELP Irishguy
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 482
Knee Deep in Regs
FWIW- It's been a few years since I was in indirect-lending, but in the past, we never required the Insurance disclosure on Gap or service maintenance agreements, and VSI doesn't protect the borrower in any way, so I would think the disclosure is not needed.
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