Thanks in advance for any help provided.

Is the LPMI fee required to be listed on the Closing Disclosure? Section 1026.38 (f) would seem to indicate that it is based on "all loan costs associated with the transaction". In 1026.38 (f)(2) it says "itemization of the services and corresponding costs for each of the settlement services required by the creditor for which the consumer did not shop in accordance...". When we look at RESPA definitions (1024.2), settlement service includes "(10) Provision of services involving mortgage insurance". Am I interpreting these incorrectly?

Anything we could find to support otherwise was from HUD FAQs prior to TRID but please let me know if I missed something.

If it seems to be a gray area, is it most often listed on the CD or do most leave it off the CD?

Really not sure how you can make an argument otherwise. All required costs, payable by the borrower, seller or other party has to be included. There is no grey area.

Thanks so much! Appreciate the quick response.

Circling back to clarify another aspect of the previous question.

In the cases where the rate is increased to compensate for the cost of the LPMI, is it still required to itemize the cost in Section B or is it considered disclosed because it's included in the rate? Or is it somehow considered a 'Lender’ cost given the way it is offered to the borrower, not a Borrower cost being paid by the Lender?

I have found in previous postings that the LPMI did not have to be disclosed because it was included in the rate but I am having trouble understanding how to support that, if so.

Thanks in advance!

Well, going back and digging into this further, the disclosure of LPMI is not really addressed in the TRID rules. Of course, there is the required disclosure required under the Homeowner's Protection Act letting them know the applicant's options for a loan with and without the coverage. So, I am not sure it would be disclosed. If you do disclose it, it would be a matter of whether or not it was a Section B charge, as an upfront charge, or under prepaids, if potentially partially refundable.

I am not currently working with any lenders that use LPMI, so I am not sure how this is handled as an industry standard. Maybe someone else might chime it that deals with this and has received some guidance from their examiners.