When a customer decides to purchase credit life & disability insurance, normally the bank pays the premium and we finance the premium amount as part of the loan. We put this on line 905 of both the GFE and HUD settlement. Would this be listed as POC or included in the total settlement charges? Thanks.

It would be part of the settlement charges because the customer is paying for it through the settlement (premium added to the loan amount) and hopefully you are including the premium in calculating the HOEPA status and giving the proper insurance disclosure under Reg. Z 226.4 to avoid it being a finance charge.

Dan, I pulled this up on a search since I had the same question today...I agree the premium would be on the settlement statement but would it not be included under the "Disbursements to Others"?

You are correct. I should have left out the word "charges". But the words settlement and charges sometimes automatically go together for me when talking RESPA. The question referred to the premium being shown as POC and it is not POC. It is being paid out of the settlement proceeds.

I am getting ready to send a memo to our loan officers about this because I keep seeing more and more where the credit life premium is included in the total estimated settlement charges on the GFE and in the total settlement charges on the HUD. These are all included in their loan amount so I am going to tell them to not include the premium on the GFE and on the HUD to just list it under the "Disbursements to Others" which will show it as part of the settlement of the loan. Please tell me if I have my head on straight with this?!