Escrow for a High-priced Mortgage?

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Question:

We are doing a loan to a daughter, with the mother as co-signer using the mother's home (in which the daughter does not reside) for collateral. This will be a high-priced mortgage. Do we need to escrow?

Answer:

You need to review the definition of consumer in 226.2 and its Commentary. If the mother is a consumer under the definition, the HPML requirements will apply. In the above scenario, since the mother is directly obligated on the note, I would opine she is a consumer and subject to the HPML requirements.

First published on BankersOnline.com 9/13/10