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Escrowing on Mortgage Loan that is a HPML

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Question: 
We are completing a mortgage Loan that is a HPML and we are escrowing taxes. Can the customer opt out of escrowing after one year of payments?
Answer: 

226.35(b)(2)(iii) Cancellation. A creditor or servicer may permit a consumer to cancel the escrow account required in paragraph (b)(3)(i) of this section only in response to a consumer's dated written request to cancel the escrow account that is received no earlier than 365 days after consummation.

But that doesn't mean that the bank is required to honor any request to opt-out.

First published on BankersOnline.com 9/12/11

First published on 09/12/2011

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