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#2259590 - 09/10/21 10:00 PM Consumer Sales of Insurance
Auditgal Offline
Junior Member
Joined: Dec 2014
Posts: 42
I'm sure this has been addressed before but my search skills are not working very good.

If a bank is only charging VSI to the borrower (no GAP or credit life purchased) then they should not have the borrower sign a Purchase Insurance disclosure should they?

Also, if a loan officer is not licensed by the state to solicit credit life, GAP or any kink of limited lines producer, then they should not be soliciting if the only insurance product on the borrower's charges is VSI?

I can't find an "insurance" definition in Reg H Subpart H to help me out.

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#2259591 - 09/10/21 10:25 PM Re: Consumer Sales of Insurance Auditgal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,946
Galveston, TX
If the lender requires and is charging the consumer for VSI, then they are not selling insurance to the consumer. The insurance only covers the lender.

For a definition of insurance and if a loan officer needs to be licensed, you would have to look to State law.
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#2259593 - 09/10/21 10:34 PM Re: Consumer Sales of Insurance rlcarey
Auditgal Offline
Junior Member
Joined: Dec 2014
Posts: 42
Thank you - I know it is late on a Friday. What about GAP insurance? That would be voluntary I suppose so the bank would have the borrower choose, but to solicit it do they have to be licensed by the state to solicit or sell it? If no, then does the two disclosures under Reg H (Federal Credit Application for Insurance and Purchase of Insurance disclosure) even apply?

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#2259599 - 09/11/21 11:35 AM Re: Consumer Sales of Insurance Auditgal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,946
Galveston, TX
GAP insurance requires disclosures. State law determines if individual licenses are necessary.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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