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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Escrows on Higher-Priced Mortgages Small creditor exemption
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#1824413 - 06/18/13 01:37 PM Small creditor exemption
4newt Offline
Gold Star
Joined: Nov 2003
Posts: 277
East Texas
We definitely qualify for the small creditor exemption. We had/have so few escrows that we opted to claim our exemption and stop escrows for future applications. My question is that now we have a borrower who needs to have his terms modified and he has escrow. This is just a modification of terms and is not a refinance. The officer and borrower want the escrow to continue. Since this is a modification of an existing (prior to June 1) loan, there should be no problem with continuing escrow. Am I right? Thoughts?

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Escrows on Higher-Priced Mortgages
#1824485 - 06/18/13 02:55 PM Re: Small creditor exemption 4newt
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Was a HPML always an HPML until refinanced. A modification does not impact that status.
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#1824499 - 06/18/13 03:18 PM Re: Small creditor exemption rlcarey
4newt Offline
Gold Star
Joined: Nov 2003
Posts: 277
East Texas
Great. I just needed another opinion before this goes forward. Thanks!

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#2012047 - 05/05/15 02:35 PM Re: Small creditor exemption 4newt
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
moved to private
Last edited by OnTheEdge; 05/05/15 03:11 PM.
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