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Available Cures if HPML is Closed w/o Escrow?

Question: 
Are there any available cures if an HPML is closed without escrow?
Answer: 

Answer from Randy: There is no prescribed regulatory cure.

Answer: 

Answer from Andy: This doesn't mean remedial actions are not warranted. You can make a bad situation as best it can be. Investigate if you can establish an escrow either under your current documents or revised ones (if needed) and decide if this should be pursued. You'll also want to understand how this happened, put controls in place to avoid it happening again, indicate if there were other cases of the same error, and train staff so they better understand the requirements. Lastly if your examiners question it, point out how this was found and that (assuming it does) your compliance program is working because it was found, and corrective actions were put in place.

First published on BankersOnline.com 7/23/12

First published on 07/23/2012

Filed under: 
Filed under compliance as: 

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