HPML -Abundance of caution

Posted By: Patricia

HPML -Abundance of caution - 11/29/12 04:23 PM

The bank made a loan on a residential property which is a HPML and are escrowing for taxes and insurance and also took another residence as an abundance of caution. Question -- is the bank required to escrow on the property that was taken as an abundance of caution also?
Posted By: raitchjay

Re: HPML -Abundance of caution - 11/29/12 04:27 PM

You're required to escrow for the primary residence only.
Posted By: Jemele

Re: HPML -Abundance of caution - 04/19/16 02:46 PM

Somewhat unrelated but we did a CD-secured loan to purchase a new primary residence. After the loan was originated, we added the primary residence as collateral at the borrower's request. Would we be required to add escrow at the time we took the property as collateral?
Posted By: rlcarey

Re: HPML -Abundance of caution - 04/20/16 01:14 PM

No - but I would be worried about the regulators accusing you of skirting the regulations.
Posted By: Jemele

Re: HPML -Abundance of caution - 04/20/16 02:12 PM

Okay, thanks! I agree, we had the evasion discussion and felt comfortable that we could demonstrate to regulators that we weren't evading requirements.