Betsy, you say your shop is selling the insurance, but not during the initial contact with the customer. If you are selling insurance after underwriting the loan and communicating the decision to the customer, then you do not need to give the insurance disclosures per the Insurance Sales Q & A (Question 2a). If that's the case, then the trick is going to be documenting that in fact you did not solicit the insurance prior to communicating the decision. And you still have the problem of how to control the dealer.
I also agree with kcarter, these do not sound like indirect deals to me. If these are not indirect and the dealer is the one selling the insurance, he or she may be deemed to be acting "on behalf of" your bank which would also trigger the disclosures, although it would depend on the facts. If the dealer sells the insurance product, does he or she get the commission rather than your bank?
Sounds like you have some work to do. Good luck.
The opinions expressed are mine and not those of my employer