It appears to me that the requirements of the 10/1 insurance disclosures could be met by adding the box with the appropriate disclosures to a credit application and adding a sentence above the signature line stating that the customer acknowledges that the disclosure was discussed orally and in writing. There does not appear to be requirement that the disclosures be in a form that that the customer may keep. Any thoughts?

I received a sample yesterday from a form company that has done just that to their credit applications. It would be helpful, but doesn't cover the NOT, NOT, NOT, NOT, MAY disclosure which we are planning to do at the same time as the anti tie-in disclosure. My understanding also is that we are not required to give the customer a copy of the disclosure(s).

Just a thought to keep in the back of your minds, I think at least one state insurance law requires that the insurance disclosures are a separate document from the credit documents.

cwilliams.........

You said:

"I received a sample yesterday from a form company that has done just that"....i.e. included the credit disclosure in their pre-printed credit applications.

Would you mind disclosing the name of that form company? You can email me if you want to.....shirleyw@asbonline.com.

Thanx.

I do not believe you need to give the customer a copy, but you must have a signature from applicant and co-applicant verifying they received the disclosure.

A good example would be a Visa application. Does your bank offer insurance from another company with the Visa application? and did that company require your Visa application be revised with the disclosure? But was there a way to provide the customer with a copy or was the customer's signature sufficient? This example was from our Visa applications, but they also needed updating for Reg Z.

Opinions are mine, not my employer.