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Non-deposit Signs on IDIs’ Premises

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  • #344713
    lucasta
    Participant

    The Final Rule requires non-deposit signs if both insured deposits and non-deposit products are offered within the IDI’s premises. Are the following considered non deposit products – credit life insurance sold by loan officers and AD&D Insurance (added feature of a checking account) – that would require the non-deposit sign to be posted in loan officer offices and CSR desks? Note: Our associated paper disclosures have the disclosures.

    #344736

    Per the FDIC website: https://www.fdic.gov/resources/deposit-insurance/financial-products-not-insured. It speaks to life insurance. However; Credit life insurance is not life insurance.
    Their names are nearly identical, and both kinds of insurance policies make payouts in the event of a death. But that’s essentially where the similarities end.

    Life insurance covers the policyholder and makes payouts to their survivors upon their death. They make monthly premiums that create a cash value.
    Credit life insurance covers a loan and benefits its lender by paying off the remainder of the loan if the borrower dies or is permanently disabled before the loan is paid in full.

    Neither Credit Life nor AD&D are considered deposits in the definitions. Life Insurance is considered a deposit and would require the non-deposit sign.

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