The Bureau added the requirement for an addendum for post-consummation construction loan inspection fees. But it has not addressed post-consummation payment of builder's risk premiums. Therefore, since it's not a finance charge and it's not paid at or before closing, I don't think it gets disclosed. I am certainly open to opposing views.
John S. Burnett
Professional Compliance Nerd since 1976
Bankers' Threads User #8