Answer:
No, there is no exemption within Reg. Z for properties of more than twenty-five acres.
First published on BankersOnline.com 5/24/10
Reg Z HPML & Escrow Requirement
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Question:
After 4/1/10, if a loan is considered a first-lien HPML for purposes of Reg Z, does the escrow requirement still exist if the property contains more than twenty-five acres? Since RESPA exempts properties of twenty-five acres and greater, and also covers the escrow rules, is this a valid exemption for HPMLs as far as escrows are concerned?
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