[Marcella]

when credit life is sold outside of the loan, auto deduct from a checking, the credit insurance disclosure should it indicate that the customer is not obtaining credit insurance for the loan?

thanks

[rcooper]

I’m assuming the loan has already closed and the borrower now wants credit life? And, if you offer credit life, the borrower has probably already received disclosures and signed the form stating they don’t want credit life. Assuming this is your bank’s practice, your file, and the fact that the insurance was purchased after closing, should be enough to indicate it wasn’t required as part of the transaction.

Don’t forget the Consumer Protection in Sales of Insurance disclosures. See https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=4cf4f0f3dd01875260a4abb198bcf3ad&tpl=/ecfrbrowse/Title12/12cfr343_main_02.tpl

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