We recently stopped offering credit life insurance for our loans. Our Financial Services area does not offer this product either but would offer a term life insurance policy as an alternative. If the customer comes to the loan officer and inquire about insurance, we would refer them to the Financial Services area so that they can shop for term life insurance products.
Since we are not offering the credit life insurance product anymore and our Financial Services area doesn't sell it, are we still required to provide the Federal Credit Application Insurance Disclosure to our customers? I would think that we don't need to unless a customer inquires about insurance, then we would need the disclosure to be provided to the customer.
What is your opinion on this?
I have a balloon note that has matured. It had credit life. The loan will be renewed with credit life. Is it considered a HPML because we are financing the premiums?
Concerning a mortgage loan with voluntary credit life insurance, do I disclose the premium fee on the Good Faith Estimate?
On our consumer notes we have the credit insurance clause that the customer signs when signing the note, and on the note is also the Federal Sale of Insurance Disclosure that the customer signs if he/she decides to get the Credit Life or Disability Insurance. When printing the documents, it prints the Federal Credit Application Insurance Disclosure. All this is in our software from Arta Lending. If all this information is on the Arta Note, do we have to print and have the customer sign the disclosure also?
We have changed lending software providers. We require VSI insurance on all titled property loans. Our previous software included VSI on the Purchase of Insurance Disclosure; our new vendor does not include this disclosure for VSI purchase, only Credit Life and GAP Insurance Purchases. Should VSI be disclosed on the Purchase of Insurance Disclosure?
Is there a reg that specifically states that one must have the Credit Life box to state whether you do or do not want Credit Life on a commercial note?
We have some consumer loans where the customer did not sign for credit life insurance so we treated the premium as a prepaid finance charge and completed an APR calculation. Can the reimbursement be credited to their loan or does the reimbursement need to be paid directly to the customer? Is there a time frame after we discover the error and if so, where does it state the time frame in the regulation?
Do we need to provide insurance disclosures to a customer who purchased credit life A/H insurance on a loan with a business related purpose?
Can a consumer purchase credit life and disability insurance on a single pay note?
Are there restrictions to how much incentive a loan officer may be paid for the sale of credit life and A and H insurance products?