Financing Credit Insurance

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    This question was just submitted by one of my seminar attendees:

    Does Title Insurance fall into the forbidden category of “ financing of credit insurance”, as set forth in 1026.36 (i)?

    Answer: Title insurance is not “credit insurance” for purposes of1026.36(i). The term “credit insurance” includes credit life, credit disability, credit unemployment, or credit property insurance, or any other accident, loss-of-income, life, or health insurance, or any payments directly or indirectly for any debt cancellation or suspension agreement or contract, but excludes credit unemployment insurance for which the unemployment insurance premiums are reasonable, the creditor receives no direct or indirect compensation in connection with the unemployment insurance premiums, and the unemployment insurance premiums are paid pursuant to a separate insurance contract and are not paid to an affiliate of the creditor.

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