Answer:
If the loan is subject to Reg Z and falls within the realm of 226.35, the consumer does not have the option to opt out of the escrow requirements.
First published on BankersOnline.com 1/03/11
Customer Chooses to Pay Taxes and Not Escrow
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Question:
I understand that Reg Z requires us to set up an escrow account for HPMLs. Can a customer choose to pay the taxes and insurance and not have it escrowed? My customer is a rancher and pays all her insurance and taxes with proceeds from the sale of cattle once a year. Her insurance covers all of the farm and operations, not just the house.
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