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HPML Escrow Requirement

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Question: 
Under the new HPML rules, most of our loans will be required to have the customer escrow for taxes, insurance, etc., for a minimum of twelve months. We handle mobile homes, and many times customers will pay their homeowner's insurance premium prior to closing for two to three years in advance. Practically all of these customers would seek to cancel their escrow requirements after the first twelve months has been reached. If this were to be the case, would an escrow account need to be established for the insurance portion, since they already paid the premiums?
Answer: 

There are no exceptions in 226.35 or its Commentary.

First published on BankersOnline.com 6/21/10

First published on 06/21/2010

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