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#2090271 - 07/27/16 08:54 PM Homeowner's, Loan Estimate, Prepaids on Refi
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
I can't seem to get a definitive answer on this... when you are doing a refi - how are you handling the homeowners' insurance on the LE? I understand that §1026.37(g)(2) requires "an itemization of the amounts to be paid by the consumer in advance of the first scheduled payment..."

Let's say that you're doing a refinance in March and the insurance is paid annually in January -- would you disclose the 12 month premium under prepaids on the LE? We require evidence of insurance but we didn't "technically" require the payment of 12 months of insurance that the consumer paid. But we DO require insurance - I'm talking in circles here!

The reason I question this is how it "messes" with the cash to close. It seems confusing to include the HOI as part of the cash to close.

Thanks!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2090322 - 07/28/16 12:48 PM Re: Homeowner's, Loan Estimate, Prepaids on Refi NoJustNo
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
If we have current insurance on a refi, we do not quote insurance on the LE. If insurance renewal will be due around the time of closing, we do, because it's an expense they need to consider and depending, may require renewal before closing. If it's a refi from another bank or just equity loan and we have no insurance details, we quote it because we will require either a new policy or a transfer of the existing policy.
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My opinion only. Not legal advice.

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#2090525 - 07/29/16 01:02 PM Re: Homeowner's, Loan Estimate, Prepaids on Refi RR Joker
NoJustNo Offline
100 Club
Joined: Oct 2013
Posts: 221
Midwest
Thanks, RR! That seems to be a good way to determine when to include or not to include in the prepaids section. Thanks for your input!

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