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Does the solicitation of owner’s title insurance trigger the credit insurance disclosure? If so does the disclosure of this insurance on the GFE for a purchase transaction count as solicitation?
If your bank is offering/selling the insurance then I would say the disclosures would be triggered. I do not believe simply listing owner’s title on the GFE, as required by regulation, is a solicitation of insurance. However, other practices you have in place may be a solicitation. The FDIC regulation is 12 CFR 343 or the applicable regulation of your regulator. FRB: 12 CFR 208.80; OCC: 12 CFR 14; Saving Associations 12 CFR 136.
Here’s a link to ecfr where you can find these regulations: https://www.ecfr.gov/cgi-bin/text-idx?SID=3355ebc2e6ac3beeaccafd165da8dbe7&tpl=/ecfrbrowse/Title12/12tab_02.tpl
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