I talked with someone from FI-SI and was told that they do not believe that the insurance rule applies to them. He indicated that FI-SI is talking with the regulators now to get an opinion. In the meantime, their banker clients who disagree with their opinion either have to stop offering their checking account/insurance program OR try to wait it out and see what the reply is OR make some other decision.
I would be interested in hearing other opinions about whether FI-SI is covered.
My latest reading still says they would be as "any other institution that sells, solicits, offers, advertises an insurance product..."