The information contained in this topic should not be deemed to constitute the provision of legal advice from PennyMac.
Correspondent clients are advised to consult with their legal counselor or compliance managers for additional information, interpretation and/or requirements related to Section 32 of Regulation Z.
For Agency loan transactions, a “high cost-high fee” mortgage is a purchase, rate/term or cash-out refinance loan secured by the consumer’s primary residence, second home or investment property which has points and fees that exceed the greater of 5% of the loan amount or a maximum dollar amount of $1000.
Correspondent clients should refer to Regulation Z, Section 226.32, the “Homeownership and Equity Protection Act”, and their legal counsel for further information, interpretation and/or related federal, state and jurisdictional requirements.
PennyMac prohibits the financing of any premiums or fees for credit insurance (such as credit life insurance) or a single fee debt cancellation agreement.
Credit insurance includes: credit life, credit disability, credit unemployment, or credit property insurance, or any other accident, loss of-income, life, or health insurance, or any payments (directly or indirectly) for any debt cancellation or suspension agreement or contract.