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#2170863 - 03/29/18 03:57 PM Work out loan- escrow
Dodge Offline
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Joined: Mar 2010
Posts: 266
We are refinancing a loan as part of a workout agreement between the lender and the customer. The customer does not want to escrow and the lender has agreed, if we could, not to escrow the insurance & taxes.

The new loan will be an HPML and if this was a normal loan we would escrow. Since this is considered a workout loan, we are not increasing the interest rate or advancing new money, can we exempt escrow?

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Lending Compliance
#2170879 - 03/29/18 04:28 PM Re: Work out loan- escrow Dodge
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
If the workout agreement is excluded under 1026.20(a) from being considered a refinance, then none of Regulation Z applies.
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#2170885 - 03/29/18 04:37 PM Re: Work out loan- escrow Dodge
Dodge Offline
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Joined: Mar 2010
Posts: 266
Thank you for your response!

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