[jprater]

The CFPB TILA-RESPA Guide shows that we should lump the flood insurance premium with homeowners insurance when disclosing on the Loan Estimate and Closing Disclosure.

We have always broken them out, for example on page 1 of the LE under the Estimated Taxes, Insurance & Assessments section we would normally show ‘Other: Flood Insurance’. But based on the CFPB Guide we should lump the total of both homeowners and flood insurance together and just include that total under homeowners insurance.

We do not have a substantial amount of flood loans, but feel this does not make sense and could cause some confusion to the consumer as flood insurance and homeowners insurance are two very different things. Thoughts?

[jholzknecht]

Section 2.2.3F of the TILA-RESPA Guide to the Disclosure Forms states, “Homeowner’s Insurance includes flood insurance.” But neither the Guide, the regulation or the Commentary state that the flood insurance premiums must be combined into a single number. In my opinion disclosing the standard homeowners premiums as “homeowner’s Insurance” and the Flood Insurance as “Other – Flood Insurance” adequately states the costs, and arguably, is an even more thorough disclosure of the insurance cost.

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