I was under the impression that you had to escrow for HPML apps taken on or after April 1.

I just took a training that said, closed on or after April 1.


Any takers?

We were probably in that same training from Harland. It's my understanding that escrow only applies to HPML loans where the APPLICATION was taken on or after April 1st, the same as your understanding!

She scared me to death! I'm gonna have to re-do all my GFEs for the last week or so.

David Dickinson's Guru question here, says apps taken on or after 4/1.

We were in the same training. Where can we go to support our understanding of apps taken on or after April 1?

Same training here.

I'm emailing the trainers for all the RESPA training I've taken that the bank has paid for in the last year. I've printed David's guru question from here. I'm "building my case".

It's in 226.1's Commentary.

Let me just copy & paste that here as it's a little hard to find...


1. Effective dates . The Board’s revisions published on July 30, 2008 (the “final rules”) apply to covered loans (including refinance loans and assumptions considered new transactions under § 226.20) for which the creditor receives an application on or after October 1, 2009, except for the final rules on advertising, escrows, and loan servicing. But see comment 1(d)(3)-1. The final rules on escrow in § 226.35(b)(3) are effective for covered loans (including refinancings and assumptions in § 226.20) for which the creditor receives an application on or after April 1, 2010; but for such loans secured by manufactured housing on or after October 1, 2010.

Thank you for that...it's always nice to see it in writing!