A servicing platform is configured to review PMI only when a borrower calls about it. Loans that reach the scheduled 78% point without a call keep paying the premium. What does the configuration miss?
Correct Answer
B) Automatically terminate PMI at 78 percent if current
Why this is correct: The Homeowners Protection Act (HPA) governs Private Mortgage Insurance (PMI). A core requirement is that servicers must automatically terminate PMI on the date the principal balance of the loan is first scheduled to reach 78 percent of the original value of the property securing the loan, provided the borrower is current on their payments. The compliance review finding that the loan schedule has reached this automatic termination point triggers this specific duty. The correct action is to "Automatically terminate PMI at 78 percent if current." Why the other choices are wrong: "Treat government mortgage insurance as conventional PMI" is wrong because government mortgage insurance (like FHA MIP or VA funding fees) is not governed by the HPA's PMI cancellation rules; it has its own, different requirements. "Ignore mortgage-insurance costs when comparing loan options" is wrong because MLOs must provide accurate Loan Estimates and Closing Disclosures that include all costs, including mortgage insurance, for proper comparison; ignoring them would violate disclosure rules. "Assume the PMI automatic termination condition is met because the borrower satisfied the separate rate-lock requirement" is wrong because the automatic termination under the HPA is based on the amortization schedule reaching 78 percent loan-to-value and the borrower's payment status, not on unrelated loan terms like a rate lock. Exam tip: Remember the HPA's two key PMI termination triggers: automatic at 78% LTV (if current) and borrower-initiated request at 80% LTV (if current and with a good payment history). Government insurance is a different topic.
Why This Is the Correct Answer
The correct response is "Automatically terminate PMI at 78 percent if current" because Lines 76-85; CFPB PMI cancellation page, automatic termination section.
Why the Other Options Are Wrong
Option A: Treat government mortgage insurance as conventional PMI.
Treat government mortgage insurance as conventional PMI. is not correct because it does not apply the rule tested by this file scenario.
Option C: Ignore mortgage-insurance costs when comparing loan options.
Ignore mortgage-insurance costs when comparing loan options. is not correct because it does not apply the rule tested by this file scenario.
Option D: Assume the PMI automatic termination condition is met because the borrower satisfied the separate rate-lock requirement.
This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.
Memory Technique
Homeowners Protection Act PMI rules: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
Match the file facts to Homeowners Protection Act PMI rules; do not choose an exception or shortcut that skips the required rule.
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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