On the recordMay 20, 2010
The gentleman is correct that we would expect the Federal Reserve Board, and, in time, the bureau, to exempt any mortgage insurance premiums that are required to be paid after closing that might otherwise be covered, consistent with the exemption authority under paragraph (7)(A). Post-closing mortgage insurance premiums are distinct from points and fees charged at the time the loan is obtained, and those post-closing premiums are not contemplated to be covered under this section.
