I am reviewing my bank's force-placed insurance notices wth the new requirements effective January 10, 2014. In our first notice, we give an estimated cost of the force-place insurance.
1024.37(c)(2)(ix)(A) states: "(ix) A statement that insurance the servicer has purchased or purchases:
(A) May cost significantly more than hazard insurance purchased by the borrower;" A bit later in the regulation, 1024.37(c)(4)states that "Additional information. A servicer may not include any information other than information required by paragraphs (c)(2) of this section in the written notice required by paragraph (c)(1)(i) of this section. However, a servicer may provide such additional information to a borrower on separate pieces of paper in the same transmittal."
Am I understanding this correctly that we CANNOT state an estimated force-place insurance cost in the first notice?
Thank you for your help. ~Elizabeth F~