ICBA has submitted in a weekly report that disclosures on insurance products must be distributed to customers beginning April 1.

That's correct. For a link to the regulation that requires the disclosures, and some discussions about the particulars, go to these threads:

General Discussion about the Insurance Rules

Discussion of Applicability to Credit Life

I'm still finding lots of bankers who have not heard about the new rule.

I guess I'm not sure how, or if, this would affect our Bank.

We don't offer Credit Life and we don't do mortgage loans and therefore don't deal with PMI.

We do "force-place" insurance, but I see in the pre-amble in the federal register that this type of insurance is excluded from the rules.

That leaves me with Title Insurance and Flood Insurance.

Title Insurance names the Bank as insured even though the customer must pay for it. In the rare case of our doing a purchase money consumer loan, the consumer arranges for their owner's policy through an outside Escrow company. We don't care as long as we get our ALTA or CLTA.

Flood Insurance is a very, very rare occurance, and if it does happen, we tell our customer to go see their insurance agent to get it taken care of.

So, do I need to fire up the Dog & Pony show on this issue, or can I just stick to my Privacy project?

Two points:
1. The banking trade associations have just sent a letter to the regulatory agencies asking for a delay of the 4/1 effective date, and also asking that credit insurance (life, A&H, disability, unemployment) be exempted from the regulation because the GLBA statutory provision behind the reg doesn't require that credit insurance be covered.

2. I think Bonnie can concentrate on Privacy -- and her HMDA/HOEPA comment letters.

I heard that the mandatory compliance date for the Insurance Disclosures has been postponed. Does anyone have any definite information regarding the new deadline?

It has been postponed to October 1. I made another posting about the new effective date on one of the other threads that relates to these insurance rules.

The agencies all agreed to the postponement today.