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#1372090 - 04/09/10 06:12 PM 2nd Mtg. HPML
In Need of Help 101 Offline
Platinum Poster
Joined: Jan 2006
Posts: 574
Okay...our bank has decided not to escrow. BUT, we have an application for a second mortgage loan (first mtg. is being escrowed)that appears that it will be a HPML.

We can still make this loan...correct? Of course, as long as we underwrite adequately, etc.

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Lending Compliance
#1372140 - 04/09/10 06:36 PM Re: 2nd Mtg. HPML In Need of Help 101
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Sure.
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#1396371 - 05/26/10 04:04 PM Re: 2nd Mtg. HPML David Dickinson
Ski Offline
Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
We have an applicant who wants to give us a second on their primary residence. Another Financial Institution has the first and it is NOT being escrowed.

If our second is an HPML, do we have to escrow?

Thanks

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#1396466 - 05/26/10 05:31 PM Re: 2nd Mtg. HPML Ski
Cowboys Fan Offline
Power Poster
Joined: Dec 2002
Posts: 4,616
SC
No, the mandatory escrow requirement only applies to 1st mortgages. 226.35 See (b)(3)
Last edited by Cowboys Fan; 05/26/10 05:32 PM. Reason: added link
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