CA 99-11 (7/01/99) FRB Community Affairs Letter indicates that Regulation Z commentary would be availed regarding the impact of rounding on the 78% threshold related to automatic termination of PMI.
I researched Reg Z in an attempt to locate the exact commentary to no avail and the recent guidance on HPA compliance dated August 2015 (CFPB) does not include specific guidance regarding rounding.
Can anyone point me in the right direction or provide their perspective? For example, if rounding to determine 78%, I believe we should select 77.58% from the below. And if that is correct, that the insurance should be cancelled "on" the corresponding date within the loan's amortization schedule.
I welcome your thoughts and if you can point me to the guidance, it would be greatly appreciated.
77.32%, 77.58%, 77.84%, 78.1%