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Required Insurance Sales Disclosures

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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 too use ARTA. The one document is an application document and must be provided to the consumer before an insurance product is solicited or sold. See FDIC Rules & Regs 343.40(b). The disclosure printed on the note is required by 343.40(a).

First published on 9/06/10

First published on 09/06/2010

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