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#539763 - 04/27/06 11:12 PM Credit Insurance Disclosure on Consumer Loans
Compliance Queen Offline
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Joined: Mar 2006
Posts: 21
It was just brought to my attention that the switch for the
Credit Insurance Disclosure on Consumer Loans was turned off the end of last year and none of our loan since then have had this disclosure on them. Is this a disclosure that is actually required? If so do we need to get the customers signature, or showing proof we mailed the dislosure to the customer enough documentation?

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Lending Compliance
#539764 - 04/28/06 01:36 PM Re: Credit Insurance Disclosure on Consumer Loans
ToTo Offline
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Joined: Apr 2004
Posts: 595
OZ
Yes, if you want to exclude credit insurance from the finance charge, it is a required disclosure, see 226.4(d). The only way to avoid inclusion of credit insurance in the finance charge is to give the proper disclosure. If you did not include the proper disclosures and did not include credit insurance in the finance charge then you have underdisclosed the finance charge which would require reimbursement of the excess finance charge that was not disclosed.

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#539765 - 04/28/06 02:30 PM Re: Credit Insurance Disclosure on Consumer Loans
Compliance Queen Offline
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Joined: Mar 2006
Posts: 21
Even though we do not offer this product?
Last edited by :o); 04/28/06 03:37 PM.
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#539766 - 04/28/06 07:45 PM Re: Credit Insurance Disclosure on Consumer Loans
ToTo Offline
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Joined: Apr 2004
Posts: 595
OZ
No. Sorry, I misunderstood your question.

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