[kmeade]

Are you required to escrow HOA dues when HPML rules require escrows?

[rcooper]

Kathy,
Sorry for the delay in responding. For an HPML you’re only required to escrow for taxes and insurance. However, it would make sense to include the HOA fees as well.

1026.35(b) Escrow accounts. (1) Requirement to escrow for property taxes and insurance. Except as provided in paragraph (b)(2) of this section, a creditor may not extend a higher-priced mortgage loan secured by a first lien on a consumer’s principal dwelling unless an escrow account is established before consummation for payment of property taxes and premiums for mortgage-related insurance required by the creditor, such as insurance against loss of or damage to property, or against liability arising out of the ownership or use of the property, or insurance protecting the creditor against the consumer’s default or other credit loss. For purposes of this paragraph (b), the term “escrow account” has the same meaning as under Regulation X (12 CFR 1024.17(b)), as amended.

[Author]

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