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#1887625 - 01/16/14 01:46 PM 2nd Mortgage HPML
Lu Offline
Platinum Poster

Registered: 04/11/02
Posts: 597
If we have a second mortgage HPML, we don't have to escrow because it is a second? Do we have to do the interior appraisal? Is there any other requirement that we have to meet?
We don't pre-payment penalties or negative amortization.
"If you only laugh and enjoy life when your problems are all solved, you'll never enjoy life."

Escrows on Higher-Priced Mortgages
#1888726 - 01/21/14 02:53 PM Re: 2nd Mortgage HPML [Re: Lu]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 32434
Loc: Cape Cod
The HPML escrow requirements in 1026.35(b) only apply to first-lien HPMLs.

The appraisal requirements in 1026.35(c), however, apply both to first-lien and junior-lien HPMLs.
John S Burnett

#1891027 - 01/28/14 09:48 AM Re: 2nd Mortgage HPML [Re: Lu]
sfx Offline
100 Club

Registered: 03/01/06
Posts: 110
Is there a requirement to escrow for flood on a second?

#1891082 - 01/28/14 10:30 AM Re: 2nd Mortgage HPML [Re: Lu]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 54320
Loc: Galveston, TX
Under the proposed regulations:

However, if the first lienholder is not required to or otherwise does not escrow flood insurance premiums and fees for adequate insurance coverage for the residential improved real estate or a mobile home, the proposed rule would require the regulated lending institution in the second lienholder position to escrow required flood insurance premiums and fees, unless such regulated lending institution qualifies for an exception from the escrowing provisions.
The opinions expressed are my own, take them or leave them.