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#486493 - 01/20/06 02:11 PM Consumer Insurance Disclosure
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
I have searched through multiple posts on this topic, but am not completely comfortable with drawing a conclusion. In situations where there are multiple borrowers obtaining credit insurance (could be borrower and co-borrower, or borrower and co-signer), are we allowed to provide the disclosure to only one of those persons? Previous posts seem to indicate that we may provide the disclosure to one person only. But, I don't feel this fits the intent of the disclosure rules.

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Lending Compliance
#486494 - 01/24/06 01:52 PM Re: Consumer Insurance Disclosure
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Quote:

I have searched through multiple posts on this topic, but am not completely comfortable with drawing a conclusion. In situations where there are multiple borrowers obtaining credit insurance (could be borrower and co-borrower, or borrower and co-signer), are we allowed to provide the disclosure to only one of those persons? Previous posts seem to indicate that we may provide the disclosure to one person only. But, I don't feel this fits the intent of the disclosure rules.


Still hoping for some comments on this one. Any takers? Please?

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#486495 - 01/24/06 05:46 PM Re: Consumer Insurance Disclosure
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
I've read both the preamble to the rule and the Interagency Q&A that came out 9/01, and I cannot find it addressed. I can't tell you what we do, because my current employer doesn't sell any type of insurance product during the application process.

If I were establishing a policy, I would probably require each consumer who is actually buying insurance to acknowledge the insurance disclosure. I would probably allow any of the borrowers to acknowledge the credit disclosure.
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Opinions are mine and not necessarily my employer's.

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