I just became aware of a LPMI program, which the MI is obtained through the Investor by increasing the rate to the borrower. As a result, MI is not financed through the loan amount, and there is no monthly MI amount that the borrower would pay.

Would our institution still need to provide the applicable HOPA disclosure to the borrower?

Would our institution still need to provide the applicable HOPA disclosure to the borrower?

Absolutely and for LPMI these disclosures must be given no later than when the commitment to make the loan is made. See Section 4905.

Many thanks Dan.

Are there any RESPA disclosures required? Does it have to go on the GFE and HUD?

LPMI is paid by an increased interest rate so there shouldn't be anything to disclose separately on the GFE or HUD.