Please help, I researched this a little but when you start looking at Reg. X, you know it always turns into a labyrinth!
When escrowing is it required to include Property Taxes and Hazard Insurance (if each of these are a condition of approval)? Or can you just pick and choose what you or the borrower would like to escrow for? The one I’m looking at is a volunatary escrow account.
Right off the top of my head, the only restriction like you are talking about has to to with HPMLs. Sounds like the one you are looking at is not a HPML, so you should be find to escrow as the customer wants, assuming that you don’t have anything in your policy that would limit that.
True this isn’t an HPML and we don’t have anything in our policy that mandates what accounts are required w/in escrow accounts. It just threw me off a little bit, it’s so unusual to only escrow for one account rather than both.
The previous replys are completely accurate, but let me add – if you require an escrow for either property insurance or property taxes then must also escrow for flood insurance. If the escrow is voluntary, not required, then this is not an issue.