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A question we received:
I am working on a high priced loan. The buyer is purchasing a rental home and is using a rental home as collateral for the down payment. Do I have to escrow on both properties?The Higher Priced Mortgage Loan (HPML) escrow requirement only applies to a loan secured by a first lien on the borrower’s principal dwelling. I assume these are non-owner occupied rental properties so they will not be the consumer’s principal dwelling. If that is the case, the HPML escrow requirement would not apply. If this is a business purpose loan, Reg Z will not apply – see section 1026.3 to help you determine if you have a transaction that is exempt from Reg Z.
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