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?
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?