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We have a lot of Amish Loans in our Market area in which we accept amish aid policies. Right now for the insurance amount we don’t put any amount down, on the loan estimate will we need to know how much their contribution is towards their amish aid plan? this may not be for homeowner’s insurance as a lot of times they only pay an amount when there is a need in that district, or they amount they pay could be for a healthcare need.
Matt,
As I am certain that you are aware Regulations Z and the Official Commentary do not mention Amish Aid, and I am not ware of any provide guidance the CFPB may have issued. Although I am familiar with Amish Aid there is littler depth to my knowledge on the topic. I was under the impression that insurance was provided by the church and no individual premiums are paid. If there are scheduled payments my answer may differ.
A safe approach may be to disclose typical homeowners insurance premiums for your area on the Loan Estimate. If at closing typical insurance is not selected and “no cost” Amish Aid” is relied on then no cost would be reflected on the Closing Disclosure and the cost from the Loan Estimate used in the good faith analysis would also be zero.
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