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Auto loans, Debt Cancelation Agreements, and Insurance Sale Disclosures

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We have begun offering GAP (Debt Cancellation Agreement) for auto loans. We are disclosing the cost to comply with Reg Z, however, do we also have to give insurance sale disclosures to the borrowers?

No. A Q&A memo was released by the FDIC (as well as the other agencies) in September 2001. Question 1a indicates that "the regulation does not apply to force placed insurance." The Q&A was included in the FDIC's FIL 842001 (9/27/01) and in OCC Bulletin 200143 (9/14/01).

First published on 3/17/03

First published on 03/17/2003

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