Can debt cancellation be offered by a bank subsidary?

Debt Cancellation products at one time were required to be offered through a subsidiary to insure the stability of the institution. In 1995 the OTS stated that a bank "itself" could offer the products if it met the following conditions.

1) The association retains no risk related to debt cancellation upon any sale of the loans.
2) An association offering debt cancellation must either obtain insurance to cover its risk of loss or establish reasonable actuarial resreves or a combination of both.