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We are starting to escrow for our consumer loans and we don’t know what to put for homeowners insurance on the GFE. Usually, on a refi, we put POC because the borrower just pays it on their own. Now, we have renewals where we are requiring escrow and we don’t know if we should call the homeowners insurance financed or POC (it will affect the APR). I don’t know if it makes a difference what they are doing with the initial deposit, financing or paying???
Charges may be listed as POC on the HUD, but should not be listed as POC on the GFE. As for the initial escrow deposit, I think it would depend on how the customer is actually funding the initial deposit. They are probably either paying in cash at closing or financing the initial escrow deposit. In my opinion, neither of these would be POC.
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