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April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina

May 15
Managing Electronic Information - From A to Zettabyte
Fred Menge



Topic Options
#1670079 - 02/27/12 11:32 AM Escrow
MSMITH10 Offline
100 Club

Registered: 09/09/10
Posts: 159
If we have a 6 M loan with 15 year amortization, would we excrow?

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Lending Compliance
#1670090 - 02/27/12 11:24 AM Re: Escrow [Re: MSMITH10]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
If it's a HPML secured by a first lien, yes.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1670095 - 02/27/12 11:42 AM Re: Escrow [Re: MSMITH10]
MSMITH10 Offline
100 Club

Registered: 09/09/10
Posts: 159
Regardless of the term? Is this because of the amortization or does the term never make a difference? We normally do not escrow if term is less than 1 year.

What if we have a 6 M interest only HPML secured by first lien?

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#1670104 - 02/27/12 11:35 AM Re: Escrow [Re: MSMITH10]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
There is no exemption in 1026.35 for short term financing.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1670111 - 02/27/12 11:53 AM Re: Escrow [Re: MSMITH10]
MSMITH10 Offline
100 Club

Registered: 09/09/10
Posts: 159
How would you calculate the excrow payment on a 6 month term? Take the 12 month premium and divide by 6?

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#1670131 - 02/27/12 11:56 AM Re: Escrow [Re: MSMITH10]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
You would still calculate based on the guidance in 1024.17.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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