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September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen



Topic Options
#1078528 - 11/07/08 09:19 AM Escrow Shortage
Rosebud123 Offline
Platinum Poster

Registered: 10/09/03
Posts: 645
Loc: Florida
If a client has an escrow shortage can we give them a loan for the shortage and charge interest. Commercial or Residential?

I am thinking that residential we cannot.

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Lending Compliance
#1078568 - 11/07/08 09:41 AM Re: Escrow Shortage [Re: Rosebud123]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49739
Loc: Galveston, TX
You have to follow the escrow rules in RESPA for residential loans subject to RESPA.

Commercial is wide open unless prohibited by State law. I guess if someone can't pay thier escrows, I would question why you would make them another loan?
_________________________
The opinions expressed are my own, take them or leave them.

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#1078577 - 11/07/08 09:46 AM Re: Escrow Shortage [Re: rlcarey]
Rosebud123 Offline
Platinum Poster

Registered: 10/09/03
Posts: 645
Loc: Florida
good point. What the lender wanted to do is increase the loan amount if the bank pays for the taxes.

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#1078622 - 11/07/08 10:07 AM Re: Escrow Shortage [Re: Rosebud123]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49739
Loc: Galveston, TX
If you are talking about a commercial loan, you would have to look to your loan contract or escrow agreement for guidance.

It would be prohibited under RESPA.
_________________________
The opinions expressed are my own, take them or leave them.

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