Escrow Disclosure and Payments

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Question:

I have a construction to permanent one time closing. This is an HPML. When do I do the Initial Escrow Disclosure and collect for escrows? When do I begin the escrow payment?

Answer:

If it's a HPML, then the escrow account must be established at the time the loan is closed because construction permanent loans are not exempt. I haven't dealt with one time closings in over ten years, but as I recall, the monthly escrow payments would begin with the first scheduled P&I payment and the escrow analysis year began with that date. We would collect the reserves at consummation.

First published on BankersOnline.com 1/03/11