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HPML Escrow for Additional Collateral

Home Forums Truth in Lending/ Regulation Z HPML Escrow for Additional Collateral

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  • #5652
    rcooper
    Keymaster

    A question we received from a member:

    If we are making a real estate purchase loan that is also secured by the co-signers home they live in, are we to escrow on both properties? The cosigner’s home does not have an outstanding mortgage anywhere else.

    #5653
    rcooper
    Keymaster

    If the co-signer is a consumer as defined in Reg Z (also see commentary) and this is their principal dwelling you will need to escrow for that property as well. Also, regardless if the co-signer meets the general definition of consumer, he/she is a consumer under the Right of Rescission rules if he/she is pledging his/her principal dwelling as collateral.

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