What regulatory issues do we need to cover on a form used by the bank to refer our customers to our insurance agency affiliate? For example, when we have a customer such as an applicant for a mortgage loan we would like to refer them to our insurance agency affiliate for a quote on homeowners insurance. We will only collect the consumers name, address, and phone #, and we'll obtain the consumer's signature for affirmative consent before sending the form to the affilate, so I think it complies with FCRA and FACT Act. But I'm not sure if we need anything else from the guidelines for non-deposit investment products (NDIP) or anything else that I may be missing.

Do we need to add any additional disclosures on the referral form? Thanks.

You'll need the RESPA form Affiliated Business Arrangement Disclsoure.

Is anyone else referring bank customers to an insurance agency affiliate? If so, what kind of disclosures are you giving the customer when you take their name and phone number etc for the referral?