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Our bank does not make HPMLs and therefore does not escrow for customer property taxes or insurance. On the estimated taxes, insurance & assessments section of the loan estimate and closing disclosure, should we still put a dollar figure,check boxes for property taxes & insurance and answer no for “in escrow” or can this section be left blank?
Yes, you would still need to disclose the costs even if you are not escrowing for them. See 1026.37(c)(4) and 1026.38(c).
Here’s a link to the eregulation: https://www.consumerfinance.gov/eregulations/1026.
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