[Vicki Kramer]

Hi. Our policy & procedures state that the Federal Sale of Insurance Disclosure is required for consumer loans that have VSI, even if no credit life/A&H was sold. This is required because we do not allow the consumer to choose/purchase from any other source – the Bank charges it on all consumer loans with applicable collateral for which we require full coverage hazard insurance on. We also include it in the APR.

I know that FDIC Part 343 Consumer Protection in Sales of Insurance is the main regulation to consider but I also based our P/P on Reg Z’s Supplement I to Part 1026 4(d)9 & 10.

Do we need to change P/P or is this correct?

1) Require Federal Sale of Insurance Disclosure when VSI is sold
2) Include the VSI charge in the APR

Thanks in advance for your help!

Topic

[Kimberly Boatwright, CAMS, CRCM]

Hi Vicki:

After looking over the sections you reference in your question, I would agree with the approach you have taken. However, if you are concerned about any legalities, you should consider reaching out to legal counsel, so you have everything covered.

Best,
Kimberly

NOTICE: This email message, including any attachments, is intended only for the addressee, and may contain confidential and privileged information either as protected work product or confidential client information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, do not read, copy, retain, or disseminate this message or any attachment, and please contact the sender by reply e-mail or at 888.760.5646 and destroy all copies of the original message and attachments. Neither the transmission of this message or any attachment, nor any error in transmission or misdelivery shall constitute waiver of any applicable legal privilege.

THIS EMAIL AND ITS ATTACHMENTS DO NOT CONSTITUTE LEGAL ADVICE

[Author]

Replies