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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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