New HPML Escrow Exemption
Is your financial institution required to establish escrow accounts for certain first-lien HPMLs? For some institutions, this can be quite a challenge! While there are loan types that are excluded (open-end credit, construction, etc.) from the escrow requirement, as well as, an exemption for small creditors, the CFPB recently announced an additional exemption. To qualify, you must meet certain asset size, loan volume, etc., requirements. If you are looking for a way out of the HPML escrow requirement, be sure to join us to find out all the details!