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Reg Z Escrow for Separate Tracts of Land

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I understand that Reg Z requires us to set up an escrow account for loans that qualify for HPML. If the security is made up of separate tracts of land and only one of the tracts includes the first lien on a principal dwelling are we required to escrow for taxes and insurance on the other tracts of land?

The escrow requirement of 1026.35(b)(3) only applies to the consumer's principal dwelling.

First published on 2/11/13

First published on 02/11/2013

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