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HPML Purchase from another Institution-Escrow?

Answered by: 
Randy Carey

Question: 
Our institution is purchasing an HPML from another institution that originated (06.02.2009) before the new escrow requirements. Are we now required to escrow? Or is the loan "grandfathered" (not requiring escrow after purchase) because it technically originated before April 1, 2010?
Answer: 

The fact that you are purchasing an existing loan does not impact the regulatory requirements that were in effect when the loan was originated. So the short answer is no, you do not have to escrow.

First published on BankersOnline.com 8/22/11

First published on 08/22/2011

Filed under: 
Lending
Filed under lending as: 
Escrow
HPML

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