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#1762223 - 11/29/12 04:23 PM HPML -Abundance of caution
Patricia Offline
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Joined: Mar 2011
Posts: 327
Kansas
The bank made a loan on a residential property which is a HPML and are escrowing for taxes and insurance and also took another residence as an abundance of caution. Question -- is the bank required to escrow on the property that was taken as an abundance of caution also?

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Lending Compliance
#1762228 - 11/29/12 04:27 PM Re: HPML -Abundance of caution Patricia
raitchjay Online
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Joined: Oct 2009
Posts: 8,564
OK
You're required to escrow for the primary residence only.
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#2074661 - 04/19/16 02:46 PM Re: HPML -Abundance of caution Patricia
Jemele Offline
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Joined: Aug 2004
Posts: 42
Somewhat unrelated but we did a CD-secured loan to purchase a new primary residence. After the loan was originated, we added the primary residence as collateral at the borrower's request. Would we be required to add escrow at the time we took the property as collateral?

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#2074782 - 04/20/16 01:14 PM Re: HPML -Abundance of caution Patricia
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
No - but I would be worried about the regulators accusing you of skirting the regulations.
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#2074800 - 04/20/16 02:12 PM Re: HPML -Abundance of caution Patricia
Jemele Offline
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Joined: Aug 2004
Posts: 42
Okay, thanks! I agree, we had the evasion discussion and felt comfortable that we could demonstrate to regulators that we weren't evading requirements.

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