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#2264556 - 01/11/22 01:48 PM Loss of Small Lender Exemption
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 604
With the loss of the SLE for escrowing flood, I want to understand the timeline. So the bank has to provide a notice to all existing loans that would have the option to escrow by September 30th from the list as of July 1st? In reading it I am confused because I would think if the bank has to start escrowing as of July 1st the existing customers should receive the letter prior to that date.

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Flood Compliance
#2264567 - 01/11/22 03:44 PM Re: Loss of Small Lender Exemption JobSecurity
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Nope - you are reading that correctly. You have to start escrowing for all loans that qualify as a MIRE on or after July 1st, but only have to notify existing customers by Sept 30th.
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#2264578 - 01/11/22 04:32 PM Re: Loss of Small Lender Exemption JobSecurity
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
Can i just ask.....do you mean JobSecurity that YOUR bank lost the small lender exemption....or did something else happen and there was some big announcement i missed or something?
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#2264594 - 01/11/22 07:17 PM Re: Loss of Small Lender Exemption JobSecurity
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 604
Thank you Randy! I appreciate your response. Raitchjay we just crossed the two years above the threshold, nothing exciting that you missed smile

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#2264595 - 01/11/22 07:20 PM Re: Loss of Small Lender Exemption JobSecurity
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
Ok....thanks JS.
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