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We gave an insurance notice to customers in the past, since we provided credit insurance through an affiliate. However, we have stopped offering insurance of any kind. Do we still have to provide the notice? – IBA Compliance Connection

IBA Compliance Connection

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We gave an insurance notice to customers in the past, since we provided credit insurance through an affiliate. However, we have stopped offering insurance of any kind. Do we still have to provide the notice?

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No, you should not have to provide the “credit disclosure” insurance notice if you no longer offer or sell insurance. The credit disclosure requirement applies only if you solicit, offer, or sell an insurance product or annuity in connection with an application for credit. 12 CFR 343.40(b). Because you have indicated that you no longer offer insurance, we do not believe you are required to provide this notice.