CFPB TRID Sec. 14.14 - If the creditor discloses the loan as one transaction, how are the mortgage insurance and estimated escrow disclosed in the Projected Payments table?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  If the creditor discloses the loan as one transaction, how are the mortgage insurance and estimated escrow disclosed in the Projected Payments table?
 
A:  When the loan is disclosed as one transaction and the terms of the legal obligation for the permanent phase, but not the construction phase, require mortgage insurance or escrow, the way the creditor discloses the escrow and mortgage insurance depends on whether the first column of the Projected Payments table exclusively discloses the construction phase.
 
If the first column of the Projected Payments table exclusively discloses the construction phase:
 
  • Mortgage insurance: the creditor discloses “0” in the first column of the Projected Payments table for mortgage insurance. (Comments 37(c)(2)(ii)-1 and 37(c)(2)(iii)-1)
     
  • Escrow: the creditor discloses a hyphen or dash in the first column of the Projected Payments table for escrow. (Comment 37(c)(2)(iii)-1)
 
However, if the first column discloses both the construction phase and the permanent phase payments, the amount of the mortgage insurance premium or escrow payment (if any) for the permanent phase is disclosed in the first column. (Comments 37(c)(2)(ii)-2, 37(c)(2)(iii)-1, and app D-7.v.C)
 
Note:  Mortgage insurance premiums are disclosed on the same periodic basis that payments for principal and interest are disclosed, even if mortgage insurance premiums are actually paid on some other periodic basis. (Comment 37(c)(2)(ii)-2)
 
 
This information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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