a regulated lending institution is not required to escrow if it has total assets of less than $1 billion and, as of the Act’s date of enactment, July 6, 2012, was not required by Federal or State law to escrow taxes or insurance for the term of the loan and did not have a policy to require escrow of taxes and insurance.
Sounds to me like you had a policy to require escrows to me, so you will not qualify under the exemption.
I have always wondered with all the tracking, etc. required for flood insurance, if you have the capability of escrowing, who in their right mind would not want to do it? It sure makes it easier to control.
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