Disclosing Credit Life

We do not offer credit insurance on our loans, and we have a Credit Insurance Disclosure indicating; A) I am not eligible for credit insurance B) Credit insurance is not available from lender C) If I am eligible and credit insurance is available from lender, I do not want it.
I think we are disclosing correct, maybe more than is needed. Our head of lending believes that we may not be disclosing enough.
Since we don't offer credit insurance, are we disclosing properly?

Since you don't offer Credit Life, in my opinion you don't
have to provide any disclosures. The disclosure requirements only apply as a way to exclude including the premium in the finance charge if the borrower puchases insurance.

The bank sales of insurance disclosure is required to be given prior to the sale of the credit insurance. If you do not offer it, then you are not attempting to sell it and the disclosure is not required. 208.84 (c) (1) timing states that the disclosures must be provided before the completion of the initial sale. The other disclosure is required at the time the consumer applies for an extension of credit with which credit insurance is offered or solicited. As neither is the case, no disclosures are required. hope this helps.