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Escrowing Pre-HPML Loans: Reg/Compliance Rules

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Question: 
We have older (pre HPML) loans on our books for which we would like to begin escrowing for insurance and taxes because we have had to pay these in the past, then add the premium and taxes back to their loan balance. Could you please direct me to information dealing with regulatory and compliance requirements with which we would have to comply to begin escrowing on these loans?
Answer: 

If you make the escrows mandatory, you would have to follow all the rules outlined in RESPA, Regulation X 3500.17.

First published on BankersOnline.com 1/23/12

First published on 01/23/2012

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