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#1258288 - 09/29/09 12:30 PM HPML and escrow
AuditorK Offline
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Posts: 962
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I was asked a question the other day that I think I know the answer too, but I can't find anything to support it.

If we make an HPML between 10/1/09 and 3/31/10, we won't need to start escrow on those loans come 4/1/10 correct? Escrow would only be required for loans originated on or after 4/1/10? In essence, we have a period of 6 months that we only have to comply with the other restrictions (repayment ability, prepayment penalties)?

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#1258314 - 09/29/09 01:07 PM Re: HPML and escrow AuditorK
AuditorK Offline
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Posts: 962
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Nevermind...found a reference to this in the preamble to the final rule. Excuse my premature posting blush

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#1258600 - 09/29/09 05:22 PM Re: HPML and escrow AuditorK
TEL Offline
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Joined: Feb 2009
Posts: 160
Where was the reference and what was the answer?

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#1258613 - 09/29/09 05:33 PM Re: HPML and escrow TEL
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
In the final rule, the preamble before the actual changes to Reg Z, it states:

The final rule requires escrows for all covered loans secured by site-built homes for which creditors receive applications on or after April 1, 2010 , and for all covered loans secured by manufactured housing for which creditors receive applications on or after October 1, 2010.

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