We offer credit life insurance on loans and I'm wondering if we need to follow the same rules as far as the "setting" as we do with NDIP investment products. For example should brochures and materials about credit life insurance not be placed on Personal Banker's desks because they take deposits also and they have FDIC signs on their desks?

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For example should brochures and materials about credit life insurance not be placed on Personal Banker's desks because they take deposits also and they have FDIC signs on their desks?

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IMO it's ridiculous but yes. It is a NDIP.

Super old thread, but I did not find anything newer on this topic that had a different answer. My understanding is that credit life insurance, in general, is not Retail NDIP.

You can see in the OCC handbook on Retail NDIP that it does not cover:

[This booklet generally does not apply to a bank’s insurance and annuity products that do not have an investment component.]

Then it says -- "For information on bank sales of insurance and annuity products that do not have an investment component, refer to the “Insurance Activities” booklet of the Comptroller’s Handbook.

Then, when you refer to the Insurance Activities handbook, it places credit life insurance under the purview of these activities, i.e. of the types of activities that do not have an investment component.