Skip to content
BOL Conferences
Thread Options
#29885 - 08/28/02 06:50 PM TILA & RESPA
Anonymous
Unregistered

Question:

If I require a customer to have Hazard Insurance, am I required to disclose that on the HUD-1 and on the TILA? Is that considered a finance charge under TILA?

Can you let me know what sections this would be located in too? Thanks.


Return to Top
Lending Compliance
#29886 - 08/28/02 07:11 PM Re: TILA & RESPA
RGS Offline
Platinum Poster
RGS
Joined: Jul 2002
Posts: 689
Home of the 8 time NCAA Champ ...
The hazard insurance must be on the GFE and the HUD-1 (with the appropriate "POC" designation on the HUD-1). However, this may be excluded from the finance charge.
_________________________
Kentucky basketball isn't a matter of life and death, it's much more important than that.

Return to Top
#29887 - 08/28/02 08:30 PM Re: TILA & RESPA
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,749
On the Net
Put it on the HUD-1/1A and GFE. They act as the itemization for the Reg. Z.

And as to exclusion of the cost as a FC, look to §226.4 Finance charge.
(2) Premiums for insurance against loss of or damage to property, or against liability arising out of the ownership or use of property, may be excluded from the finance charge if the following conditions are met:

(i) The insurance coverage may be obtained from a person of the consumer’s choice, and this fact is disclosed.

(ii) If the coverage is obtained from or through the creditor, the premium for the initial term of insurance coverage shall be disclosed. If the term of insurance is less than the term of the transaction, the term of insurance shall also be disclosed. The premium may be disclosed on a unit-cost basis only in open-end credit transactions, closed-end credit transactions by mail or telephone under §226.17(g), and certain closed-end credit transactions involving an insurance plan that limits the total amount of indebtedness subject to coverage.

Check the Reg for footnotes extracted from this cite.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#29888 - 08/28/02 08:42 PM Re: TILA & RESPA
RJM Offline
Member
RJM
Joined: Jun 2002
Posts: 95
New York, NY USA
Thank you R.G Smith and Andy Z! I appreciate your input.

I looked at 226.4 in TILA before I asked the question, and it didn't appear to be clear (at least to me), and I didn't find the commentary much help either, that's why I asked.


Return to Top

Moderator:  Andy_Z