Tolerance Question

What is the tolerance level set for Property taxes that are not escrowed under the new Integrated Disclosure Rules??

Based on my study of the rule so far, it's not a closing cost that is subject to the tolerance restrictions under the new rules.

Thank You!!!

One more tolerance question...What about MIP and PMI? What are their tolerance requirements in this rule??

I appreciate your help with this!! This rule is insane!!!

I agree with John regarding Property taxes. As for MIP and PMI paid upfront, it appears they'll be subject to a 0% tolerance as the borrower won't be allowed to shop for those.

Thanks, Jerod!!

I would recommend calling the CFPB about the property taxes. The answer I was given was a bit confusing. The CFPB attorney differentiated the tolerance level depending upon whether it was a purchase or refi. With a refi being zero tolerance and a purchase being tolerance free. The reasoning, from what I could understand, being that in a purchase the prepaid taxes are a seller required item, while on a refi it's lender required.

I dutifully wrote down what he said and thanked him for his time. But still don't remain confident in that answer, so if anyone hears differently or gets more information I would love to know.

Four months later and another follow up question.

Jerod, I noticed that above you refer to MIP and PMI "paid up front". Would monthly MIP payments also be subject to 0% tolerance?

Thanks!

No. Monthly PMI/MIP payments are going to remain part of the escrow.

If I understand TRID correctly, if you collect a single upfront month's worth, that will move to zero tolerance from the 10% tolerance area it is in now.

Can I carry this one more step. If we quoted the wrong PMI in the early TIL and corrected it in the final TIL and this caused and APR tolerance issue. IS the only thing we have to do is rediclosure and wait the timeframe before closing the loan?

Bump!

Early and final TIL? Are you talking the TRID or current rules?

current and I think I figured it out!

Can I piggy back on bstritecky's question, but say it's TRID rules? LE goes out without a fee that causes APR to be out of tolerance. What are the bank's options, if any?

If we quoted the wrong PMI monthly premium in the Loan Estimate, could we correct it in a new Loan Estimate?? Or do we correct it in the Closing Disclosure and reimburse if there is an APR tolerance issue and wait the timeframe before closing the loan?

Was anyone able to figure out the answer to FLSCgirl's question? We are having a similar issue. We issued a quote for monthly PMI on an LE, the actual premium came back higher and is out of the APR tolerance. Not sure where to go from here.

First question: why did the actual premium come back higher? Did you have a valid CC that triggered it?

Otherwise, it depends on whether you're actually collecting any PMI at closing or not.
If not, the only place the number figures in is on page 1 of the LE in the total payment calculation.

With most of the PMI companies now preferring to issue ZOMP (zero up front) we don't collect the first month OR a cushion for PMI.
That takes it out of any APR calculation and makes life under TRID just a tad more bearable.

So PMI is NOT included as a PPFC if we aren't collecting anything for PMI at closing?

Not sure exactly what you mean by not collecting at closing, but if they are just making the monthly PMI payment, then you would not set this up to be included as a prepaid finance charge. However, if you have single premium upfront, or any policy that does have an upfront portion, then that would be categorized as a finance charge fee. You would also have to apply that amount to your QM and HC points and fees calculations.