Our bank currently requests the signing of a Credit Insurance Notice upon application for any deposit account product. We are trying to evaluate the number of disclosures provided and identify which are regulatory requirements. Our notice simply states that credit insurance is available on a voluntary basis through the bank, that it is not required as a factor in obtaining credit, and that the bank may not require the purchase of an insurance product or annuity in order to make a loan or extension of credit. Where can I find guidance on when this is a requirement? I have searched the internet and have not had any luck.

Do you offer insurance on your deposit products?

We do offer it on a select few deposit products, so I'm trying to find out if we are required to provide the same disclosure on all products.

My thoughts - I believe the disclosure would only be required for the products where it applies. There would be no need to give this disclosure if the consumer didn't have the option of purchasing the insurance.

That's what I thought, thanks Skittles!

Do you tie any credit cards to your deposit products?

We do not, they are separate products with their own applications.

I believe this is covered in 12 CFR 14, Consumer Protection in Sales of Insurance.

I have a related question. We do not sell credit insurance on deposit products, but our customer service representatives are being cross-trained to sell loan products. They will also sell credit protection products in conjunction with the loan products. In reading the regulatory guidance associated with insurance sales, it requires that insurance sales should be separate and distinct to the extent practical from deposit taking areas. During the deposit account opening process our CSRs do accept the initial deposit and they also have FDIC signage on their desks. I'm just wondering how other banks are handling this practice?