[TheBank]

When making a loan subject to the ATR rule what is also required to have flood insurance, would it be required to consider the increase in flood insurance premmiums expected over the next few years when determing the mortgage related costs under the general ATR rule for a large creditor? If not required, would it be recommended to do so?

[rcooper]

Reg Z says that you need to consider the premium. IMO that means the current premium, but if you know a rate will be increasing I don’t see a problem with taking a more conservative approach and using that increase as long as it is applied consistently.

[Author]

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