Hello, I seem to recall that we are not required to disclose PMI cut-off dates on ARM loans, only fixed rate loans. Does anyone know what regulation this is so that I can provide a copy to our green examiners?

Thank you and Happy Memorial Day!

Homeowners Protection Act

§4903: Disclosure Requirements (01/02/01)

(a) Disclosures for new mortgages at time of transaction

(B) if the transaction relates to an adjustable-rate mortgage, a written notice that --

(i) the mortgagor may cancel the requirement in accordance with section 4902(a) of this title on the cancellation date, and that the servicer will notify the mortgagor when the cancellation date is reached;

(ii) the requirement for private mortgage insurance will automatically terminate on the termination date, and that on the termination date, the mortgagor will be notified of the termination or that the requirement will be terminated as soon as the mortgagor is current on loan payments; and

(iii) there are exemptions to the right of cancellation and automatic termination of a requirement for private mortgage insurance in accordance with section 4902(g) of this title, and whether such an exemption applies at that time to that transaction.

...but don't forget that Reg. Z still requires you to estimate a payment schedule, including the MI renewal premiums, using all known information and your best estimate of unknown info (like future index values).