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#1477638 - 12/08/10 04:01 PM Escrow cancellation on HPML
gbkmoore Offline
Member
Joined: Apr 2010
Posts: 73
Florida
after 12 months of escrow on a HPML; can the lender cancel the escrow requirement without the consent of the borrower?
or
does the cancellation have to be intiated and/or approved by the borrower?

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Lending Compliance
#1477652 - 12/08/10 04:13 PM Re: Escrow cancellation on HPML gbkmoore
gbkmoore Offline
Member
Joined: Apr 2010
Posts: 73
Florida
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.


AFTER READING THE ABOVE: MAKES ME THINK ONLY THE BORROWER CAN INTIATE THE CANCELATION?

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#1477658 - 12/08/10 04:16 PM Re: Escrow cancellation on HPML gbkmoore
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
that would be my take, yes.
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My opinion only. Not legal advice.

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#1477750 - 12/08/10 05:32 PM Re: Escrow cancellation on HPML RR Joker
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,229
Galveston, TX
The borrower has to initiate and the bank has the option of whether to allow it.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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