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Credit Life Sale Disclosure-Signature?

Question: 
Our bank sells credit life and offers it to our clients. Is the credit life sale disclosure required to be signed by the applicant. Is there such a disclosure with no signature requrement?
Answer: 

Dan Persfull
From 343.40:

(7) Consumer acknowledgment. You must obtain from the consumer, at the time a consumer receives the disclosures required under paragraph (a) or (b) of this section, or at the time of the initial purchase by the consumer of an insurance product or annuity, a written acknowledgment by the consumer that the consumer received the disclosures. You may permit a consumer to acknowledge receipt of the disclosures electronically or in paper form. If the disclosures required under paragraph (a) or (b) of this section are provided in connection with a transaction that is conducted by telephone, you must:

(i) Obtain an oral acknowledgment of receipt of the disclosures and maintain sufficient documentation to show that the acknowledgment was given; and

(ii) Make reasonable efforts to obtain a written acknowledgment from the consumer.

Andy Zavoina:
I believe Dan's answer is what you were seeking but there is also a section in Reg Z, 1026.4(d)(3)(iv) which requires a signature or initials for credit insurance.

https://www.bankersonline.com/regulations/12-1026-004#d

(3) Charges or premiums paid for debt cancellation coverage for amounts exceeding the value of the collateral securing the obligation or for debt cancellation or debt suspension coverage in the event of the loss of life, health, or income or in case of accident may be excluded from the finance charge, whether or not the coverage is insurance, if the following conditions are met:

(iv) The consumer signs or initials an affirmative written request for coverage after receiving the disclosures specified in this paragraph, except as provided in paragraph (d)(4) of this section. Any consumer in the transaction may sign or initial the request.

First published on 08/16/2020

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