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I processed a worksheet with PMI, and the PMI dropped off before the LTV reached 78%. What happened?

The federal Homeowners Protection Act provides for three potential PMI drop off points. First, under certain circumstances, the borrower can request cancellation when the loan is either scheduled to, or actually does, reach 80% of the original value of the property securing the loan. This is called the “cancellation date."  Second, PMI must be automatically terminated by the servicer when the principal balance is first scheduled to reach 78% of the original value of the property of the  loan. This is called the “termination date.” Third, the HPA provides for “final termination”.

Are Closing Protection Letter fees classified as prepaid finance charges?

Generally speaking, a charge is a finance charge unless it is specifically excluded.  You might be able to squeeze this into the exemption afforded by Reg. Z Section 226.4(c)(7) for title examination and related charges, but that is a stretch.  The better, more conservative approach would be to treat this type of charge as a finance charge.

On what closing documents does the CA CFL license number need to appear?

According to the California Department of Corporations, the CFL license number needs to be disclosed on at least one document that is to be signed by the consumer.  It does not necessarily need to be disclosed on the deed of trust if another document already discloses it.  However, we currently disclose the CFL license number on the Note, Good Faith Estimate, TIL and the CA Finance Lender's Law Statement of Loan.

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