The company that handles our debt cancellation product sent out a letter stating that as long as the monthly fees were not financed and not added to loan principal and do not accrue interest, that the fee can remain at the level monthly payment amount.
From the CFPB’s commentary on the final ruling: Finally, the
Bureau again emphasizes that a credit insurance product with a level or levelized premium is not prohibited by this final rule.
Are we ok to continue with the monthly level payments for debt cancellation? As long as we do not advance money to pay the fee on the borrower’s behalf if the borrower fails to pay the fee before the end of the monthly period?