I support the prohibition on financing SINGLE PREMIUM credit insurance on mortgage loans. This option is clearly less consumer-friendly than other options.
I DO NOT support the prohibition against adding monthly premiums to the borrower's mortgage loan balance. Although there is a small additional interest charge assessed to the borrower as a result of adding the monthly premium to the mortgage balance, this amount is relatively small. The required monthly loan payment is increased enough to compensate for the additional premium such that the loan still pays off on schedule. This is a convenient way for the borrower to obtain and pay for coverage that they may find valuable.
Prohibiting this practice would unnecessarily burden consumers, and would likely cause our financial institution to cease offering this coverage on mortgage related loans.
Comment on CFPB-2013-0013-0001
This is comment on Proposed Rule
Loan Originator Compensation Requirements under the Truth In Lending Act: Prohibition on Financing Credit Insurance Premiums; Delay of Effective Date
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