I am reading through the October 1, 2014 FAQ’s from the CFPB Outlook Live Webinar and it states that the flood insurance premium and the hazard insurance premium are included under the homeowner’s insurance premium for purposes of the escrow section on page 1 of the LE and the Taxes, Insurance and Assessments section of the LE on page 1. They are quoting 1026.37(c)(4)(ii) per section 1026.4(b)(8) being premiums or other charges for insurance against loss or damaged property.

So if I know that the property is in flood zone at the issuance of an LE, then we must include the flood and hazard ins prem together under Homeowner's Insurance instead of showing the flood insurance in the Other line in that same section?

The software I am testing, I have listed it separately and it lists it separately on the LE and the CloD too and takes that information and defaults it to the Initial Escrow Payment at closing section. So if this is correct, how do we show the premiums with the appropriate amount and months when the premiums may have different policy and expiration dates?

Most of the time we don't know if it is in a flood zone till we pull the flood but if it is a refi of an existing loan with us...we will know that information.

This is not making sense to me! Do I have this all mixed up?

Brenda - did you ever get an answer to your question? I'm re-reviewing this today, and I've got myself mixed up. I guess I'm just not understanding why it wouldn't go in other (that just makes more sense).

I did not get one from BOL but after further research and re-reading the reg and commentary, the flood and hazard premiums are to be quoted together under Homeowner's Insurance in the Estimated Taxes, Insurance and Assessments section of the LE. I have been testing with our different software vendor and they are dropping the flood in homeowner's on one and another is not. We have 2 LOS and 2 doc prep....and not all of them are on the same page.

I believe it is going to take us all as an industry to go live with our systems and then correct along the way. Sad way to go about it, but the CFPB has been NO darn help. They aren't the ones trying to complete these forms and get it right based on some parts of the reg being silent or vague.

This has been one of the worst regs to implement!

I am done venting!

In complete agreement with you on this reg! A 5-page CD could have been a one pager and called a "closing summary." FWTW.