If you failed to properly cancel/terminate the PMI under HOPA then you must refund the unearned premiums. Make sure you review HOPA to understand the difference between the Borrower Cancellation and Automatic Termination timing requirements, especially the 79% and/or 50% automatic termination requirements. If you missed the automatic termination requirements then you will need to refund all the unearned premiums that have been collected.https://www.law.cornell.edu/uscode/text/12/chapter-49
(f)Return of unearned premiums
Not later than 45 days after the termination or cancellation of a private mortgage insurance requirement under this section, all unearned premiums for private mortgage insurance shall be returned to the mortgagor by the servicer.