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Before the team acts on a branch training session, a risk reviewer must address TILA Loan Estimate Disclosure. Which response is most defensible?

Correct Answer

D) Include mortgage-insurance costs in product comparison

Why this is correct: A Loan Estimate must provide a complete and accurate picture of loan costs to facilitate comparison. Mortgage insurance (MI) is a significant borrower cost that varies by product. The correct choice, "Include mortgage-insurance costs in product comparison," ensures the borrower can make an informed decision by seeing the full financial impact of different loan options, including upfront premiums, monthly premiums, and how they affect the APR. Why the other choices are wrong: "Use the purchase price as the only factor when PMI depends on LTV and program terms" is wrong because the cost of Private Mortgage Insurance (PMI) is primarily driven by Loan-to-Value (LTV) ratio and credit score, not just the purchase price. Ignoring these factors leads to an inaccurate cost estimate. "Assume lender-paid MI has no cost because it is not shown as a separate monthly premium" is wrong because lender-paid MI is typically exchanged for a higher interest rate. The cost is built into the rate and payment, and must be disclosed and compared against other MI options. "Compare MI options without considering rate, payment, and cancellation treatment" is wrong because a meaningful comparison requires evaluating all cost components: the interest rate, the total monthly payment (including any MI premium), and the potential for MI cancellation, which affects long-term cost. Exam tip: For MI questions, always consider the total cost to the borrower: upfront fees, monthly premium, interest rate, and duration of the coverage.

Answer Options
A
Use the purchase price as the only factor when PMI depends on LTV and program terms.
B
Assume lender-paid MI has no cost because it is not shown as a separate monthly premium.
C
Compare MI options without considering rate, payment, and cancellation treatment.
D
Include mortgage-insurance costs in product comparison

Why This Is the Correct Answer

The correct response is "Include mortgage-insurance costs in product comparison" because PMI options affect borrower cost and depend on loan type, LTV, and mortgage-insurance rules.

Why the Other Options Are Wrong

Option A: Use the purchase price as the only factor when PMI depends on LTV and program terms.

This choice is a tempting shortcut, but it conflicts with PMI and mortgage-insurance options because the file still needs the required documentation, timing, or rule-based review before the action is taken.

Option B: Assume lender-paid MI has no cost because it is not shown as a separate monthly premium.

This choice is not the best answer because it applies the wrong file step for PMI and mortgage-insurance options; the governing rule is tested by the correct option.

Option C: Compare MI options without considering rate, payment, and cancellation treatment.

This choice is a tempting shortcut, but it conflicts with PMI and mortgage-insurance options because the file still needs the required documentation, timing, or rule-based review before the action is taken.

Memory Technique

PMI options and mortgage-insurance costs: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.

Exam Tip

For PMI and mortgage-insurance options questions, separate the required file step from plausible sales, timing, or documentation shortcuts.

Common Mistakes to Avoid

  • -Choosing an internal exception instead of the governing rule
  • -Treating preliminary or informal facts as a substitute for required documentation
  • -Answering from a familiar but unrelated mortgage topic
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