We have decided to discontinue selling credit life in connection with credit products and are going to sell debt cancellation products with a monthly billed premium. We are told that these are not viewed as insurance products and can be sold by anyone not just licensed agents. We are passing the liability to a third party insurance administratior but the contract will be between the bank and the customer. If this isn't insurance, do we still have to make the disclosures required by the new Insurance Rules, not FDIC, not Guaranteed....etc.?

I wouldn't think so because this is not insurance. How does your state law look at this?