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#2192787 - 09/17/18 05:48 PM Builder's Risk- APR?
Luvs2Comply Offline
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Joined: Aug 2018
Posts: 18
Would builder's risk be considered an APR fee? I am thinking no, but would just like to confirm.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2192796 - 09/17/18 06:11 PM Re: Builder's Risk- APR? Luvs2Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
1026.4(d)(2) Property insurance premiums. Premiums for insurance against loss of or damage to property, or against liability arising out of the ownership or use of property, including single interest insurance if the insurer waives all right of subrogation against the consumer, 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. (A creditor may reserve the right to refuse to accept, for reasonable cause, an insurer offered by the consumer.)

(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 §1026.17(g), and certain closed-end credit transactions involving an insurance plan that limits the total amount of indebtedness subject to coverage.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2192798 - 09/17/18 06:25 PM Re: Builder's Risk- APR? Luvs2Comply
Luvs2Comply Offline
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Joined: Aug 2018
Posts: 18
We disclosed it as a prepaid on the LE, so not technically a shoppable fee according to TRID. The customer may choose whoever they want to for the builder's risk insurance, assuming that the coverage is sufficient.

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#2192809 - 09/17/18 07:01 PM Re: Builder's Risk- APR? Luvs2Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I am assuming that builder's insurance in your State also names the consumer and not just the builder and bank as loss payees and you are requiring the consumer to purchase this?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2192841 - 09/17/18 09:01 PM Re: Builder's Risk- APR? Luvs2Comply
Luvs2Comply Offline
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Joined: Aug 2018
Posts: 18
You're correct

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