For the Periodic Statement disclosure requirements related to the Explaination of Amount Due as set forth under 1026.41(d)(2), if an FI escrows PMI premiums, would the monthly premium be included under "Escrow" or under "Fees and Charges"?

It seems to me that PMI premiums are both a charge (under the definition of finance charge set forth in Reg Z 226.4(b)) and an escrowed amount however, including under both "Escrow" and "Fees and Charges" on the Periodic Statement would be duplicitive/misleading/confusing.

Bump

I can't find anything in the rule that would support one way or the other, but I would probably include it as an escrow item. Essentially, anything that is paid into escrow in my mind would appear in the escrow field, even if it could also be a fee or charge (which is not defined in TILA for closed-end credit). That's my gut gess at least.

Since the PMI payments would be part of the annual escrow analysis, I say it goes there.