Currently we perform annual escrow analyses based on the anniversary date of the mortgage, but years ago we only performed analysis during two particular months during the year. What Reg covers this and what is stated regarding analysis? If we wanted to move to a few times a year instead of monthly, we'd have to create either a short or long analysis for customers to accomplish that but I'm hesitant to consider that change.
We had a customer come in and make a deposit over 10K to a custodial account on which she is not a signer. Whose information do we place in Section A of the CTR: the custodian's or the minor's?
I understand that Reg Z requires us to set up an escrow account for HPMLs. Can a customer choose to pay the taxes and insurance and not have it escrowed? My customer is a rancher and pays all her insurance and taxes with proceeds from the sale of cattle once a year. Her insurance covers all of the farm and operations, not just the house.
Can a borrower revoke our obligation to escrow for taxes and insurance on an HPML before the initial twelve month requirement is over?
On the new Good Faith Estimate and the HUD, since we are now escrowing on mobile homes, do we disclose and escrow the mobile home ad valorem taxes?
Does RESPA prohibit a lender from financing escrow payments for a HPML?
Is an escorw account required if the loan is under $15,000.00.(it is a high priced loan)
There has been some question about whether after the first year an escrow account is set up if a lender can collect one full year (instead of monthly) of taxes and insurance up front? Can a lender do that according to the Reg? If that is true, can you tell me exactly where to find that language in the reg?
Under Reg Z, what is the regulation regarding escrowed accounts on manufactured housing? Is it required that a buyer must pay (out of pocket) the first two months of escrow?
In a question that was posed to Patricia Cashman on 7-19-10 concerning HPML and modifications, she stated that escrow will not apply to a true modification. Could she please show me where that can be found in the regulation. I have looked and can't find this. I have this situation and I need more clarification.