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#2019601 - 06/10/15 07:06 PM Force placed hazard insurance
HuntFish Offline
Member
Joined: Jan 2010
Posts: 64
undecided
This may be located deep within the TRID forums, please forgive me if it is, but I could not find any reference. Under current RESPA, we are required to notify the borrower 2x before we force place hazard insurance. Those rules are for the current RESPA covered transactions (consumer purpose residential real estate less than 25 acres, etc). With the new rules effective August 1, that section of RESPA (1024.37) will not change, correct? It will still cover current RESPA loans OR will it change to match the August 1 loans? If stays as current, suggestions on how to differentiate the loans within loan platform/system? Has anyone else wondered about this or am I an only.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2019747 - 06/11/15 12:57 PM Re: Force placed hazard insurance HuntFish
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 956
Lost in a regulatory fog
Correct. The new TRID rules are essentially under TILA. The only sections of RESPA impacted are 6,7,8,10, and 33 (which are the disclosures being replaced). In other words all the other sections of RESPA remain the same including coverage and exemptions.

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#2019764 - 06/11/15 01:45 PM Re: Force placed hazard insurance HuntFish
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
So the only real change here is that the over 25 acre exemption from RESPA will be a thing of the past as of 8/1/15, but any loan that was not a RESPA loan when it closed won't become a RESPA loan on 8/1/15.
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BankersOnline.com
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#2019772 - 06/11/15 01:58 PM Re: Force placed hazard insurance HuntFish
HuntFish Offline
Member
Joined: Jan 2010
Posts: 64
undecided
Thank you both for your responses! So, August 1 and after,when we prepare to force place hazard insurance on a current defined RESPA loan, would it save to say we could use the form letter (appendix MS-3 of Regulation X) for loans under the new TILA rule?

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