[timob1973]

I’m trying to figure out if VSI should be considered credit property insurance. I’ve found one source that cites the CFPB as saying it is while another source says that the FDIC noted in teleconference that VSI is not a credit property insurance product and could be financed. Any help would be appreciated.

This is in regards to the new Regulation Z rules 1026.36 – Prohibition on financing credit insurance.

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[rcooper]

I would go with the CFPB’s opinion since Reg Z is now under their control. I haven’t seen anything concrete that tells us either way. But in my opinion, I believe they will consider VSI as credit insurance. This link from the CFPB, https://www.consumerfinance.gov/askcfpb/799/my-dealer-offered-me-credit-insurance-what-it.html , although addressing dealers, gives some insight to the CFPB’s definition of the different types of credit insurance.

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