Once the HPML provisions took place, we have always had HPMLs and required escrow. We have recently lowered our rate and no longer have HPMLs. Best practice would be to require escrow on all loans (since we are pros now). I guess the question is this...if we do escrow on a case-by-case basis, is there anything wrong with this?

Thanks!!

There is nothing that I am aware of that prohibits this on a case-by-case basis. But I would recommend that it be treated as and other service you may offer with regard to 'fairness and reasonable' especially if any fees are attached to the service. Basically, you would want to ensure that it you are not excluding anyone on a prohibited basis.