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#1744960 - 09/27/12 07:43 PM Escrow when not required
elebra Offline
100 Club
Joined: Apr 2009
Posts: 106
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?


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Lending Compliance
#1745022 - 09/27/12 08:51 PM Re: Escrow when not required elebra
Banker Chick Offline
Junior Member
Joined: Jul 2006
Posts: 37
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.
Opinions expressed are my own and do not necessarily reflect those of my employer.

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