As far as credit life is concerned, I think we are clear of any fair banking issues since the final rule specifically mentions that the department does not feel a product like credit life would be beneficial for covered borrowers.
"The Department believes that most, if not all, of the credit
insurance products, debt cancellation contracts, or debt suspension agreements
customarily offered to consumers are not suitable for a covered borrower because the
military services already provide insurance or other benefits to a Service member that
would adequately provide financial resources even if an event of coverage (e.g.,
disability) were to occur to the borrower. For example, a Service member currently holds
health insurance as part of his or her benefits in the Service and, if that Service member
were to become ill, the Service member still would be employed, thereby allowing him or
her (or the relevant dependent who relies on the Service member’s income) to continue to
make payments on the debts incurred without triggering a condition of the credit
insurance."
Does anyone have any opinion on not offering GAP to a covered borrower for indirect loans?
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"It's time for the Jedi to end."
Luke Skywalker