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#2189752 - 08/20/18 04:12 PM Credit Life Insurance Disclosures
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Are banks giving these out on any consumer loan request (at application) or just on certain loan products? I've always been told you give the disclosures on any consumer loan request.

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Lending Compliance
#2189760 - 08/20/18 04:43 PM Re: Credit Life Insurance Disclosures mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
What disclosure are you specifically referring to?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2189771 - 08/20/18 05:07 PM Re: Credit Life Insurance Disclosures mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
The Federal Credit Application Insurance Disclosure (as it is our LOS), stating that credit insurance is available but not required for credit extension.

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#2189788 - 08/20/18 06:03 PM Re: Credit Life Insurance Disclosures mdog76
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
You have to give them a disclosure at application if you are selling credit life insurance on the product/loan for which they are applying. If you don't sell it on that particular type of loan, no disclosure is required.

ยง 343.40 What you must disclose.

(a) Insurance disclosures. In connection with the initial purchase of an insurance product or annuity by a consumer from you, you must disclose to the consumer, except to the extent the disclosure would not be accurate, that:

(1) The insurance product or annuity is not a deposit or other obligation of, or guaranteed by, the institution or an affiliate of the institution;

(2) The insurance product or annuity is not insured by the Federal Deposit Insurance Corporation (FDIC) or any other agency of the United States, the institution, or (if applicable) an affiliate of the institution; and

(3) In the case of an insurance product or annuity that involves an investment risk, there is investment risk associated with the product, including the possible loss of value.

(b) Credit disclosure. In the case of an application for credit in connection with which an insurance product or annuity is solicited, offered, or sold, you must disclose that the institution may not condition an extension of credit on either:

(1) The consumer's purchase of an insurance product or annuity from the institution or any of its affiliates; or

(2) The consumer's agreement not to obtain, or a prohibition on the consumer from obtaining, an insurance product or annuity from an unaffiliated entity.

(c) Timing and method of disclosures--(1) In general. The disclosures required by paragraph (a) of this section must be provided orally and in writing before the completion of the initial sale of an insurance product or annuity to a consumer. The disclosure required by paragraph (b) of this section must be made orally and in writing at the time the consumer applies for an extension of credit in connection with which an insurance product or annuity is solicited, offered, or sold.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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