[shea930]

We can still sell a monthly pay insurance policy but it must be completely seperate from the loan, we can’t escrow for payments or anything right?

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[jholzknecht]

A monthly premium is clearly allowed. The borrower’s monthly loan payment would include principal, interest, and the monthly credit insurance premium. The premium would be a pass through item. If you sell a single premium policy the borrower would have to pay the full amount up front.

[tparker]

Does “dwelling” mean rent houses, mobile homes, etc…or do they mean…”principal dwelling”…Primary Residence?????

[jholzknecht]

A dwelling is a one- to-four-family unit. It may be rental property, but in order for Regulation Z to apply the loan must be for a consumer purpose. A mobile home is a dwelling. When coverage in the regulation targets a principal dwelling the agency drafting the regulations use the term “principal dwelling.”

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