We offer credit insurance to our loan customers and those who purchase it have their monthly premium added to their monthly loan payment amount. Currently, if a customer makes a payment that is not enough to cover their monthly premium, we'll assess the amount of the monthly premium to the loan as a fee and remit payment to the insurance company. Is that a practice that is prohibited under 1026.36(i)? If it is prohibited, how are your institutions handling scenarios such as this?

No one with any thoughts on the topic or no one facing the same issue? We could really use some help here.

I'd like help with this too. The February rule prohibits a creditor from financing any premiums or fees for credit insurance in connection with a residential mortgage loan, UNLESS the premiums or fees are calculated and paid in full on a monthly basis, the creditor receives no compensation, the premiums are paid pursuant to a separate insurance contract and are not paid the creditors' affiliate. Then, what is the benefit to the bank for offering this type of product? Am I missing something?