FORUM PROFILE

Anti-coercion credit insurance disclosure

Home Forums What else is on your mind? Anti-coercion credit insurance disclosure

Viewing 2 posts - 1 through 2 (of 2 total)
  • Author
    Posts
  • #3880
    ScottH
    Participant

    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?

    #3896
    rcooper
    Keymaster

    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

Viewing 2 posts - 1 through 2 (of 2 total)
  • You must be logged in to reply to this topic.