Has anyone received any guidance from the regulators as to whether they will enforce these rules on a bank's sale of PMI or Credit Life Insurance when making a loan? I believe that it will be difficult to comply with the rules on sales of these types of insurance.

I have heard both ways on PMI, but have not heard any indication that they will not enforce for credit life. Compliance for credit life will entail training your loan officers to provide the anticoercion disclosures orally and in writing at the time of application, and providing the NOT, NOT disclosures orally and in writing at the time of consummation of the loan and purchase of the credit life insurance. Doesn't seem too difficult to comply as long as the lenders do what you train them is required.

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Opinions expressed are my own, and do not necessarily reflect those of my employer.

The OCC staff in Wash D.C. has told my bank and an attorney working with the ABA that PMI is not covered -- the policy is sold to the bank for its protection (tho we pass cost on to the consumer).

Also, the ABA, CBA and other trade associations have filed a formal request that the banking agencies reconsider the coverage of credit life, A&H, etc. which currently are covered. In case you're not aware, the agencies last week delayed the effective date of the reg from April 1 to Oct 1 this year.

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Pat Patrick
Wachovia Corp. Compliance
336-732-3394
pat.patrick@wachovia.com

I just received a fax from our state bankers association indicating that the compliance deadline has been officially extended to October 1, 2001. Has anyone seen anything official from the regulators yet?

Not official from Agencies themselves, but semi-official in an Friday, 3/2 e-mail from Amer Bankers Assn Senior Counsel Paul Smith, who is the ABA guru on this subject. He said that the General Counsels of the Agencies met and agreed on Oct 1 eff date, that a Federal Register announcement has been drafted and should come out soon. I guess you could call Paul for confirmation.

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Pat Patrick
Wachovia Corp. Compliance
336-732-3394
pat.patrick@wachovia.com

I spoke earlier today with an Associate General Counsel for the Board of Governors about this issue. He would not directly confirm the delay. But he did say that the staff was giving "favorable consideration" to the request. He also said that some announcement would be forthcoming in the Federal Register next Tuesday (he thought).

Since I don't think a "NO" would be published in the FR, I think it's a good bet that the implementation will be delayed.