Is the amount of PMI shown on Huc-1 line 902, also shown on the TIL as a prepaid fc? There seems to be a conflict between the HOPA and the commentary to TIL Sec. 18(c)(1)(iv).

If the PMI is required to be reserved, is the reserve included in the PPFC?

All responses are greatly appreciated.

The PMI premium is a finance charge and the portion of the premium collected at or before closing is a PPFC. For HOPEA purposes the premiums collected at or before closing are included in your calculation.

Thanks, Dan.