We are not required to show the amount of the homeowners insurance on the GFE if the loan is a refinance and we are requiring the borrower to use the insurance they already have according to the RESPA Q&As.

So my question is do we need to show the homeowners insurance on the HUD as POC if we are not collecting anythin from the borrower?

Any guidance would be greatly appreciated.

We do.

We do not. See the Dec 2010 Roundup.

Dan, I didn't see anything about homeowners insurance in the Dec Roundup?

I am relating it to services obtained in a previous transaction.

Just list the insurance as $0. Same with all other previously obtained services.

Tagging on here, please tell me if I have this correct.

For a refinance with escrows:
1. The insurance is included in the escrow deposit shown on the GFE and in the escrow section of the HUD.

2. We also need to show the Homeowner's Insurance in Block 11 of the GFE as "XYZ Insurance - $0" and itemized on the HUD as "POC," right?

Our software vendor is telling us that step 2 is unnecessary. We don't quite believe them.

1. yes
2. no. For Refinances only, you do not show it on the GFE or the HUD. that's what Dan and the Dec Round-up are telling you. Your software provider is correct.

OK, thanks. Apparently I completely misunderstood that.

In my opinion, you do not show it. Although the 12/10 roundup refers to survey's and appraisals and lists Block 3, they also use the term "such as". If you look to the following section and apply it to the insurance, it would be my opinion that you do not reflect it further than the GFE $0.00 (no name required). We all know HUD's interpretations are narrow-minded, so "intent" has to be applied sometimes!

If a loan originator includes an estimate of a charge for a service on the GFE, but then uses an existing work product that was paid for in a prior transaction, then the service is not entered on page 2 of the HUD-1/1A and the GFE estimate of the charge for that service is not included on the comparison chart on page 3 of the HUD-1/1A.