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May 27, 2015
Compliance Management – Phase 1, your Program and Training
Andy Zavoina

May 28, 2015
Integrated Disclosures 101
Mary Beth Guard, John Burnett and Andy Zavoina

June 11, 2015
New Tech Advances to Improve Info Security
Susan Orr

June 22, 2015
50 Key Considerations for Integrated Disclosure Rules Readiness
Mary Beth Guard and Jack Holzkechnt

June 23, 2015
The IRS and TINs: The High Cost of Name Mismatches
Deborah Crawford



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#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: 52940
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: 52940
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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