Other than the potential for unfair treatment under UDAAP if we say we require escrow and then change our minds on a few..

Management is considering requiring escrow reserves on all federally related mtg. transactions- are there any rules (Reg. Z or other ) that would prohibit this?

Thanks for your help!

We do require escrow on all federally related mtg transactions - the examiners reviewed it when they were here earlier this month and were fine with it. That being said - it is ALL, no exceptions allowed to avoid the unfair treatment discussion...

It does require support from senior management and the board - tone from the top. There were a few LO's that pushed back when it was first implemented but they've gotten the message that it is required. They've also decided it makes it easier to verify taxes and insurance have been paid when we are cutting the checks!

Thank you for your feedback... would you mind telling me who you are regulated by.. not that it should matter but we are FDIC

Can anyone tell me if it is OK, shall we say, to categorize a certain type of loan for escrow and not all first mortgage loans?