Answer:
That is correct. Review 226.20 and its Commentary.
First published on BankersOnline.com 6/21/10
HPML Escrow on Rate Modification
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Question:
Under the new HPML regs (226.35), escrow of taxes and insurance is only required if you are "extending a loan". If we are doing a rate modification on an existing loan, HPML calculations do not apply. Is this correct?
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