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#1362810 - 03/24/10 01:31 PM Escrow 1 year rule
CompDat Offline
Platinum Poster
Joined: Dec 2005
Posts: 553
USA
Someone brought up to me that there is a rule that after 1 year the customer can opt out of Escrow. Since Escrows are now required on HPML first position owner occupied units, it seems contrarian to allow for an opt out.

To me, if a loan is designated as HPML, it is higher risk and would need the escrow. Am I crazy here?

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Lending Compliance
#1362820 - 03/24/10 01:47 PM Re: Escrow 1 year rule CompDat
CompDat Offline
Platinum Poster
Joined: Dec 2005
Posts: 553
USA
(iii) Cancellation. A creditor or servicer may permit a consumer to cancel the escrow account required in paragraph (b)(3)(i) of this section only in response to a consumer's dated written request to cancel the escrow account that is received no earlier than 365 days after consummation.

This is annoying now!

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#1362869 - 03/24/10 02:35 PM Re: Escrow 1 year rule CompDat
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,967
Bloomington, IN
The customer can request the cancellation of the escrow but you are under no regulatory requirement to approve the request.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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