A borrower requests cancellation of borrower-paid PMI after the HPA cancellation date has been reached. One mortgage payment was 35 days late eight months before this request. Does this history meet the HPA good-payment-history requirement for borrower-requested cancellation?
Correct Answer
C) The request fails: no payment 30 days late in the preceding 12 months
C. The 35-day delinquency fails the recent twelve-month test. The look-back is measured from the later of the cancellation date and request date; the revised facts make the request date controlling. Thirty days or more past due in that recent twelve-month period fails the definition. The earlier twelve-month window uses a sixty-day threshold. Scope and exceptions: This addresses borrower-requested cancellation, not a permanent bar or the separate automatic-termination test. Other cancellation conditions must also be satisfied. Source: HPA section 2(4), good payment history — https://www.federalreserve.gov/frrs/regulations/section-2-definitions.htm
Why This Is the Correct Answer
C. The 35-day delinquency fails the recent twelve-month test. The look-back is measured from the later of the cancellation date and request date; the revised facts make the request date controlling. Thirty days or more past due in that recent twelve-month period fails the definition. The earlier twelve-month window uses a sixty-day threshold. Scope and exceptions: This addresses borrower-requested cancellation, not a permanent bar or the separate automatic-termination test. Other cancellation conditions must also be satisfied.
Why the Other Options Are Wrong
Option A: The request stands: only a payment 60 days late in 12 months blocks it
It substitutes the earlier-window sixty-day threshold for the recent-window rule.
Option B: The request stands: late payments over 6 months old are disregarded
There is no six-month disregard rule here.
Option D: The request fails: any payment late by 15 days or more blocks it
Fifteen days is not this statutory payment-history threshold.
Exam Tip
Select the controlling date, then apply the correct delinquency window.
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