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#2028719 - 07/22/15 11:59 AM Escrows
Love Cruising Offline
100 Club
Joined: Mar 2009
Posts: 248
if you meet the definition of small bank, but you currently do servicing for your residential portfolio under these conditions would you need to escrow under the new flood requirements?

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Flood Compliance
#2028727 - 07/22/15 12:26 PM Re: Escrows Love Cruising
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,216
Galveston, TX
under these conditions

What conditions??? You mean you have and service escrow accounts?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2028838 - 07/22/15 03:44 PM Re: Escrows Love Cruising
Love Cruising Offline
100 Club
Joined: Mar 2009
Posts: 248
Yes, we have residential loans in our portfolio and they have escrows

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#2028847 - 07/22/15 03:56 PM Re: Escrows Love Cruising
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,216
Galveston, TX
Well, it is hard to say. You have to answer both questions A and B.

(A) That has total assets of less than $1 billion as of December 31 of either of the two prior calendar years; and

(B) On or before July 6, 2012:

(1) Was not required under Federal or State law to deposit taxes, insurance premiums, fees, or any other charges in an escrow account for the entire term of any loan secured by residential improved real estate or a mobile home; and

(2) Did not have a policy of consistently and uniformly requiring the deposit of taxes, insurance premiums, fees, or any other charges in an escrow account for any loans secured by residential improved real estate or a mobile home.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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