[mfitzpatrick]

If the bank offers, but doesn’t require escrow on Non HPML loans will we loose the small lender exception within the flood insurance rules? We currently escrow for HPML loans and have on occasion setup an escrow account for a NON HPML loan per the borrowers request. The third qualification states “Did not have a policy of consistently and uniformly requiring the deposit of taxes, insurance premiums, fees, or any other charges in a escrow account for any loans secured by residential improved real estate or a mobile home.” I’m wondering if “required” is the key word.

[rcooper]

Allowing voluntary escrows would not preclude you from meeting and utilizing the exemption.

[Author]

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