Good afternoon!

LO disclosed monthly FHA MI on initial and locked LEs as requiring 120 months of MI payments but should have disclosed 360 months of MI payments. I'm getting differing opinions from consultants as to whether now disclosing the correct MI payment stream on the CD (360 months of MI payments) is acceptable and won't require APR or finance charge tolerance issues. The APR and finance charge will be higher on the CD than on the locked LE due to the additional 240 months of MI factored in. Opinions encouraged.

Thanks!

The APR and finance charges are not really the problem. However, MI premiums are a 0% tolerance fee. That is what your concern should be.

The upfront premium was accurate in Section B. The monthly MI in the Projected Payments on the LE was the correct amount but wasn't disclosed for the correct number of months.

Oh - OK. There is no APR test between previously issued LEs and the initial CD. You just have uncorrectable errors on your LE.

What Randy said.

Thanks, all!