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2nd Mortgage w/ 1st Already in Escrow

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Question: 
We are doing a second mortgage where the first mortgage is already in escrow. 1.) Should we disclose the estimated escrow on page 1 of the Loan Estimate with No for being in escrow or should we completely leave them off since the borrower is already in escrow. 2.) On Page 4 of the Closing Disclosure how should we disclose here as well, and if we select no escrow, our only options are because the customer declined it or your lender does not offer one. Neither of these fit our situation because the customer is already in escrow with us, so they didn't decline it nor did we not offer one.
Answer: 

1). You are always required to complete the Estimated Taxes, Insurance & Assessments table on Page 1. You answer would be No.
2.. You do not offer one, if they already have an escrow account. You said "nor did we not offer one". If that was the case, then you did offer one? You do not offer one, if they already have an escrow account.

First published on 03/17/2019

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