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Reg Z Escrow Exemption

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  • #2599
    avolentine
    Participant

    According to CFPB’s preliminary list of rural or underserved counties, the county (Delaware, OK) in which my Bank extends 50% of our covered transactions is designated as such. Currently we do have 3 HPML loans in which we escrow. My question is, since we have escrowed for these loans are we now not exempt? These loans were closed after 4/1/10. (Referring to the Compliance Masters Group frontline training under Exemption (D)(1).
    Thank you!

    #3143
    jholzknecht
    Keymaster

    The new escrow rules are effective on June 1, 2013. If you bank meets all of the conditions in Section 1026.35(b)(2)(iii) then you may stop escrowing. The fact that you have escrowed on a first-lien HPML does not preclude you from taki advantage of the new exemption.

    #2983
    avolentine
    Participant

    I should have worded my question differently, if we have escrowed on loans that are not HPMLs, does this require us to continue to escrow or can we still meet the exemption requirements?

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