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December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett

January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson



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: 41139
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: 41139
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: 41139
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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