Answer:
Escrows are required for flood insurance and for higher-priced mortgage loans. A loan made in the commercial loan department for a consumer purpose (such as a CEO borrowing money for a cruise with his/her spouse) secured by residential real property that requires flood insurance would need an escrow. It is the loan purpose, not the department in which the loan is made, that determines the need for an escrow.
------------
Learn more about Jack Holzknecht and Kimberly Boatwright's Compliance for Commercial Lenders webinar.