We have decided to enter the world of mortgage lending, and received our first application today. When pricing, it appears it will be an HPML, which I know has additional requirements. When looking at the escrow exemption, I see we need to qualify for all 4 criteria. I’m good with number of transactions, asset size, and maintaining escrow accounts. However, since we’ve never done mortgage lending, we haven’t originated a covered transaction in a rural or underserved area. Does this mean we will need to escrow? I feel like we shouldn’t have to, but we don’t meet the exemption unless there is something I’m missing.
Thanks in advance!