|
 |
Final TIL - PMI Tax Included?
Answer by Dan Persfull and Richard Insley, BOL Gurus
Guru Bio
Question: Is the PMI tax included in the payment stream on the final TIL?
Answer by Dan Persfull: I have no idea what a PMI tax is, but the PMI premiums must be included in the payment stream. See the Commentary to 226.18(g)(5). Mortgage insurance. The payment schedule should reflect the consumer's mortgage insurance payments until the date on which the creditor must automatically terminate coverage under . . .
Answer by Richard Insley: Like Dan, I've never heard the term PMI tax, so unless we can get a correction (if the question is incorrectly worded) or an explanation of the nature and timing of the PMI tax, there's no way to answer this question directly. In general, Reg Z requires lenders to include in the disclosed payment schedule all amounts representing repayment of the amount financed plus all amounts that are finance charges except those amounts that must be classified as prepaid finance charges. Additionally, Reg Z permits lenders to include other non-AF/FC items such as tax and insurance escrows. Most lenders ignore this option, however, because these inflated payment schedules create the appearance that the FC and APR are understated.
First published on BankersOnline.com 4/07/08
Privacy Policy Disclaimer Recommend This Site ! Contact Us
BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.
|
|
|
Print Friendly!
Email This Article!
Discuss NOW!