Loss of Small Lender Exemption

With the loss of the SLE for escrowing flood, I want to understand the timeline. So the bank has to provide a notice to all existing loans that would have the option to escrow by September 30th from the list as of July 1st? In reading it I am confused because I would think if the bank has to start escrowing as of July 1st the existing customers should receive the letter prior to that date.

Nope - you are reading that correctly. You have to start escrowing for all loans that qualify as a MIRE on or after July 1st, but only have to notify existing customers by Sept 30th.

Can i just ask.....do you mean JobSecurity that YOUR bank lost the small lender exemption....or did something else happen and there was some big announcement i missed or something?

Thank you Randy! I appreciate your response. Raitchjay we just crossed the two years above the threshold, nothing exciting that you missed

Ok....thanks JS.