On August 4, 2015, the Consumer Financial Protection Bureau (CFPB) issued Compliance Bulletin 2015-03 (click here) to provide guidance regarding the cancellation and termination of private mortgage insurance (PMI) pursuant to the Homeowners Protection Act of 1998 codified in 12 USC 4901 et seq.(HPA), which was passed by Congress to address difficulties borrowers encountered in cancelling PMI when they had reached a certain level of equity in the property. The HPA provides specific cancellation and termination rights for borrowers and requirements that must be followed. Bulletin 2015-03 summarizes the HPA provisions but does not create any new requirements. Bulletin 2015-03 also describes examples from CFPB’s supervisory experience of PMI cancellation and termination procedures that violate the HPA or create a substantial risk of noncompliance. The following summary of Bulletin 2015-03 is not a complete description of its contents, and you are urged to read the entirety of the bulletin and the appropriate sections of the HBA cited therein.
