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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

July 15, 2015
All About Escrows
David Dickinson



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#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: 42112
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: 42112
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: 42112
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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