We received an application to purchase primary residence. Applicant has a take out commitment so we do not intend to do the permanent financing. Our loan will be in the amount of
$400,000.00 with interest only for 18 months.

Would this be considered temporary financing and exempt from RESPA?

Would an escrow account be required on this loan?

Would this be considered temporary financing and exempt from RESPA?

Yes.

Would an escrow account be required on this loan?

If HPML, yes. 1026.35 only exempts temporary loans with a term of 12 months or less.

thank you.