If I am modifying a loan to lengthen the amortization period, do I have to escrow? I am only doing a modification agreement & modification of mortgage. The loan was done previous to the escrow requirements & I wasn't sure if since I was modifying it, I needed to escrow or not.

Modifications don't require disclosures, so I don't see a tripwire for HPML requirements...It's not a new transacation.

Thank you!