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?