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Iowa Consumer Credit Code (ICCC) Informal Advisory Opinions - 1986 Archive

January 28, 1986

Offering a different APR to a consumer loan customer who purchases credit insurance in connection with a loan is not prohibited by the ICCC.  But unless the creditor could demonstrate that the purchase of the insurance was not required, the insurance cost could not be excluded from the finance charge.

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January 23, 1986

The ICCC provides that an additional charge may be made for consumer credit insurance providing life, health, and accident coverage if the insurance coverage is not required by the creditor.  However, the FTLA model forms provide for a separate choice for each type of optional insurance.  Even though these forms are not mandatory, it is the opinion of the Administrator that tying the purchase of one type insurance to another violates the ICCC.

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January 17, 1986

The ICCC permits a creditor to make an “additional charge” for title insurance on consumer loans secured by an interest in land.  The insurance laws of Iowa prohibit the sale of title insurance in Iowa.

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