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#1429289 - 08/13/10 09:17 PM Federal Sale of Insurance Disclosure
SUSANE1 Offline
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I just discovered this form on our lending platform. In what instance would you use this form?

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Lending Compliance
#1429293 - 08/13/10 09:24 PM Re: Federal Sale of Insurance Disclosure SUSANE1
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
When any type of insurance product is solicited or sold by the FI.

The FDIC version is found here:

http://www.fdic.gov/regulations/laws/rules/2000-6300.html
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1429296 - 08/13/10 09:40 PM Re: Federal Sale of Insurance Disclosure SUSANE1
SUSANE1 Offline
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THANKS, does this include credit life?

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#1429312 - 08/13/10 10:19 PM Re: Federal Sale of Insurance Disclosure SUSANE1
swiggles Offline
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Yep.
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#1429774 - 08/16/10 08:00 PM Re: Federal Sale of Insurance Disclosure swiggles
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
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Central Illinois
We have it attached to every consumer application for credit due to the following part of the reg. 343.40 What you must disclose. (c) Timing and method of disclosures.(1) In general. The disclosures required by paragraph (a) of this section must be provided orally and in writing before the completion of the initial sale of an insurance product or annuity to a consumer. The disclosure required by paragraph (b) of this section must be made orally and in writing at the time the consumer applies for an extension of credit in connection with which an insurance product or annuity is solicited, offered, or sold.

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#1429831 - 08/16/10 09:04 PM Re: Federal Sale of Insurance Disclosure Oursisnottoreasonwhy
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
You may also want to check your state laws. IN for example has their own disclosures that must be given in addition to the Federal disclosures.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1475932 - 12/03/10 05:39 PM Re: Federal Sale of Insurance Disclosure Dan Persfull
SaaL Offline
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The Texas Hill Country
Would these disclosures be required with the sale of GAP insurance?
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#1475993 - 12/03/10 06:40 PM Re: Federal Sale of Insurance Disclosure SaaL
Sheldon Hendrix Offline
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South
Yes, GAP is covered as well.

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#1476193 - 12/03/10 11:03 PM Re: Federal Sale of Insurance Disclosure Sheldon Hendrix
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The Texas Hill Country
Thanks! I was afraid you were going to say that!
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#1476690 - 12/06/10 10:18 PM Re: Federal Sale of Insurance Disclosure SaaL
swiggles Offline
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We offer IUI (Involuntary Unemployment Insurance). I suppose this would be covered as well? However, our vendor claims that our GAP product is not insurance but rather a "debt waiver product." I guess I wouldn't have a clue as to how to argue the point.....if an argument is necessary.
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#1476755 - 12/07/10 12:58 AM Re: Federal Sale of Insurance Disclosure swiggles
rlcarey Offline
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Galveston, TX
The Federal regulations do not define insurance. But (you are in Texas aren't you?) if that was the case, why do they have to be authorized by the Texas Department of Insurance to sell GAP insurance in Texas???

http://www.tdi.state.tx.us/commercial/gaplist.html

Now what you are describing may not be GAP insurance, but the Texas Insurance Code has a whole chapter devoted to this product:

CHAPTER 3501. CREDIT INVOLUNTARY UNEMPLOYMENT INSURANCE

Sec. 3501.001. DEFINITION. In this chapter, "credit involuntary unemployment insurance" means insurance that indemnifies a debtor for installment or other periodic payments on an indebtedness while the debtor is involuntarily unemployed. The term includes policy forms and endorsements that define involuntary unemployment to provide coverage and a premium charge for interruption or reduction of a debtor's income during periods of leave, whether paid or unpaid, authorized by the federal Family and Medical Leave Act of 1993 (29 U.S.C. Section 2601 et seq.), as amended, or other state or federal law.


How can they claim it is not insurance????
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1476806 - 12/07/10 02:00 PM Re: Federal Sale of Insurance Disclosure rlcarey
Dan Persfull Offline
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Bloomington, IN
Randy hit the nail on the head. It is a state law issue. IN also treats GAP as an insurance product.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1476982 - 12/07/10 04:37 PM Re: Federal Sale of Insurance Disclosure rlcarey
swiggles Offline
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They're not claiming that IUI isn't insurance. They're only claiming that GAP isn't insurance.
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The more you sweat in training, the less you bleed in battle.......

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#1476999 - 12/07/10 04:55 PM Re: Federal Sale of Insurance Disclosure swiggles
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Again that depends on state law. As I mentioned above GAP is considered insurance in IN. IN even goes as far that if you are going to sell GAP you have to get a letter from the state certifying the GAP plan has been approved and meets all the state requirements.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1477002 - 12/07/10 04:56 PM Re: Federal Sale of Insurance Disclosure swiggles
swiggles Offline
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swiggles
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Well, my heart resumed beating. I checked with DocPrep and we DO provide an Insurance Disclosure for both of those products when a sale occurs. The Credit Disclosure is automatic because it (and a copy of the Disclosure for the customer) is included in every consumer loan application.
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The more you sweat in training, the less you bleed in battle.......

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#2173021 - 04/11/18 05:23 PM Re: Federal Sale of Insurance Disclosure Dan Persfull
meeksfor3 Offline
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meeksfor3
Joined: May 2012
Posts: 57
Kentucky
Originally Posted By Dan Persfull
When any type of insurance product is solicited or sold by the FI.

The FDIC version is found here:

http://www.fdic.gov/regulations/laws/rules/2000-6300.html
[quote][/quote]

A friend says their bank give it for Lenders Title Insurance. Would the federal sale of insurance disclosure be required for title insurance? We have never given it for title insurance and an examiner has never questioned us before.

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#2173046 - 04/11/18 06:30 PM Re: Federal Sale of Insurance Disclosure SUSANE1
rlcarey Offline
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rlcarey
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Posts: 83,219
Galveston, TX
A friend says their bank give it for Lenders Title Insurance.

Find a new friend smile
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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