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We’ve been giving disclosures to loan customers about homeowners insurance. An Illinois law, 215 ILCS 5/1412, says that if we are a financial institution and offer insurance (either directly or through an affiliate), we have to give an affiliated business disclosure. We had a close relationship with an insurance company at one time, but we do not currently have any affiliate or relationships with any insurance companies. Do we need to keep giving this notice to our customers? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We’ve been giving disclosures to loan customers about homeowners insurance. An Illinois law, 215 ILCS 5/1412, says that if we are a financial institution and offer insurance (either directly or through an affiliate), we have to give an affiliated business disclosure. We had a close relationship with an insurance company at one time, but we do not currently have any affiliate or relationships with any insurance companies. Do we need to keep giving this notice to our customers?

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We do not see any reason to disclose an affiliate relationship to customers after the affiliate relationship has ended. The Illinois law you cited, 215 ILCS 5/1412, requires disclosure to customers only if your institution offers insurance directly or through an affiliate. Since your institution does not currently offer insurance directly or through an affiliate, that requirement does not apply. There are also federal disclosure requirements that could apply to an affiliate arrangement (such as the Gramm-Leach-Bliley Act disclosure requirements and the RESPA “affiliated business arrangement” disclosure requirements), but again, we see no reason that those requirements would apply after the relationship has ended.