We sell loans on the secondary market, but we will now start retaining the servicing on some of these loans. We have never escrowed on portfolio loans, but will now have escrow on the loans for which we will retain the servicing. We had previously met the exemption for not requiring escrow of flood insurance, but does that change now since we will be retaining the servicing of some loans with escrow?
I believe we are still exempt from requiring the escrow since we did not have a policy of escrowing before 2012 and are under the asset size requirements, but I want to double check my thinking.
Thank you in advance.
My views only.