Questions and Answers
When calculating the points & fees that effect the calculation to determine if the loan is subject to HOEPA or not, is the PMI Premium that is paid after closing on a monthly basis to be included in the fee total?
No. Section 32 of Regulation Z (12 CFR 226.32) describes what goes into that calculation. It says that you count only points and fees “payable by the consumer at or before loan closing” in the calculation. PMI premiums are within the points and fees calculation, but only to the extent the premium is paid at or before loan closing.
(Posted: 02/22/2008)
