Yes, you are required to include the homeowner’s insurance premiums line on Page 2 of the Loan Estimate in Section F for refinances.
Regulation Z requires that a new set of disclosures be provided whenever there is a refinancing, and in the Prepaids Section of the Loan Estimate (Section F on Page 2), the rule requires an itemization of the amounts to be paid by the consumer before the first scheduled payment. Specifically, Regulation Z requires the creditor to list the number of months for which the homeowner’s insurance premium is to be paid.
Additionally, the Official Interpretations clarify that the homeowner’s insurance line “may not be deleted, even if amounts for those labeled items are not charged to the consumer. If an amount for a labeled item is not charged to the consumer, the time period, daily amount, and percentage used in the labels are left blank.” Consequently, the homeowner’s insurance premiums line in Section F should be included on the Loan Estimate.
For resources related to our guidance, please see:
- Regulation Z, 12 CFR 1026.20(a) (“A refinancing is a new transaction requiring new disclosures to the consumer.”)
- Regulation Z, 12 CFR 1026.37(g)(2)(i) (“Under the subheading ‘Prepaids,’ an itemization of the amounts to be paid by the consumer in advance of the first scheduled payment, and the subtotal of all such amounts, as follows: (i) On the first line, the number of months for which homeowner's insurance premiums are to be paid by the consumer at consummation and the total dollar amount to be paid by the consumer at consummation for such premiums, labeled ‘Homeowner's Insurance Premium ( __ months).’”)
- Regulation Z, Official Interpretations, 12 CFR 1026, Paragraph 37(g)(2), Comment 4 (“The lines and labels required by § 1026.37(g)(2) may not be deleted, even if amounts for those labeled items are not charged to the consumer. If an amount for a labeled item is not charged to the consumer, the time period, daily amount, and percentage used in the labels are left blank.”)