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#1102695 - 12/29/08 03:31 AM Credit Life Disclosures at Application
Glutes Offline
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Glutes
Joined: Dec 2005
Posts: 597
Texas
What credit life disclosures, if any, need to be provided at application (RE transaction, customer to purchase credit life)?

We recently switched from Arta Lending to Laser Pro. Our Arta documents used to disclose the credit life premium in the early TIL disclosure and GFE, but the Laser Pro early TIL and GFE does not reflect this.

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#1102763 - 12/29/08 03:22 PM Re: Credit Life Disclosures at Application Glutes
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,390
If the purchase of credit insurance is voluntary, there are no early disclosure requirements under Reg Z because the purchase of credit insurance will not affect the APR.

The Federal Reg "Consumer Protection in Sales of Insurance" requires that you provide a disclosure at application if Credit Insurance is solicitated, offered or sold. My view is that if credit insurance is available for the type of loan requested, then it is considered offered.

I see you're from Texas. The Finance Code (Chapter 343) requires that you provide a disclosure for certain types of housing-related loans. The diclosure provides an example of the effects of financing a credit insurance premium.
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#1104530 - 12/31/08 10:53 PM Re: Credit Life Disclosures at Application swiggles
Glutes Offline
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Glutes
Joined: Dec 2005
Posts: 597
Texas
Thanks for the response Swiggles!

Looking at the Consumer Protection in Sales of Insurance reg, I find that we are providing the two disclosures required here.

However, I'm a little unsure about the Chapter 343 of the Finance Code. Is this disclosure requirement only triggered if we offer credit life on a prepaid single premium basis in conjunction with a home loan?

This is the only disclosure requirement where I see the actual insurance premium amounts being disclosed. Is there any other disclosure requirement regarding the premium?

Thanks and Happy New Year!

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