In my opinion for both VA and USDA transactions the corresponding agency transaction number should be disclosed as the “MIC #â€, and the number should be disclosed regardless of whether or not there is any fee collection for the agency.
The rules related to payment disclosures require that VA and USDA monthly payments (if any) be treated as the functional equivalent of mortgage insurance. As a result, it seems to make the most sense to also treat those loan programs as the functional equivalent of mortgage insurance for purposes of the “MIC #†disclosure even though the “functional equivalent†rule does not specifically extend to the “MIC #†disclosure. Lenders, investors and/or regulators may have differing opinions on this issue but it seems to me that disclosure of the VA and USDA numbers as the MIC # is preferable to not disclosing them.
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Just my opinion, I could be wrong. - Dennis Miller