Do you have a borrower that wants to cancel the required escrow account on their Higher-Priced Mortgage Loan (HPML)?
First you need to understand what your options are. Option #1 is that you don’t have to honor their request. You can require they keep the escrow account in place. Option #2 is to allow them to cancel the escrow account. But, they MUST meet all of the following criteria before doing so:
- It must be five years since the HPML (and required escrow) were originated;
- They must be at 80% loan to original value (not current value) of the property; and,
- They cannot be delinquent at the time of the request.
This is just one of the many topics that we will address in our upcoming “Ability to Repay, Qualified Mortgage, High-Cost & Higher-Priced Mortgage Loans” webinar. We will spend two hours walking you through the compliance requirements for these types of loans and answering your questions along the way. See you then!
See all training options here – https://www.bankerscompliance.com/banking-regulations-compliance-training/
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar, or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups, and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru.
Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports related!