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August 5, 2015
HMDA – Beyond the Input
Patricia Cashman

August 11, 2015
ABCs of HSAs
Whitney Johnson

August 12, 2015
Part I: Flood Insurance - Everything You Need To Know (including June 2015 Rules)
David Dickinson and Jerod Moyer

August 13, 2015
Currency Transaction Report (CTR): Line-By-Line for Tellers
Deborah Crawford

August 18, 2015
Disaster Recovery Revisited: 5 Things You May Not Have Considered (for a while)
David Reed

August 20, 2015
Automated Monitoring Systems: Implementation to Validation
Brian Crow

August 25, 2015
MasterCard & Reg E Error Resolution
Brian Crow



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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: 42355
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: 42355
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: 42355
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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