The explanation is a little more convoluted than what was posted. There are two points.
First, since an Owners Policy is not required by the lender to underwrite the loan, the CFPB states the word Optional must be added to that line on the new disclosure.
Second, in those states that have a Simultaneous Issue rate, the rate shown on the disclosure is not the same as the rate charged. The full rate for the loan policy will be shown, not the simultaneous rate (in most areas, the lower simultaneous rate is given on the loan). The rate for the owners policy will be calculated as the full rate of owners plus the simultaneous rate for the loan minus the full rate of the loan.
It is in trying to explain these calculations and the word optional where it may be felt the line for licensing is being crossed.
Since the lender is ultimately responsible for following all of the rules, if they state you need to be licensed, you will need to be licensed or not work for that lender. |
