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Escrow for 2nd Lien Closed-End Home Equity

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Question: 
We have a first-lien HELOC at 80% LTV. We want to offer a second-lien closed-end home equity loan at 20% LTV. Since the two add up to 100% LTV, are we required to escrow? Neither loan is a higher-priced mortgage. The first is below 1.5% APR over APOR and the second is below 3.5%. Do I need to escrow?
Answer: 

If neither loan is an HPML, any decision to escrow will be policy-driven.

First published on 11/10/2014

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