[ldoyle]

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?

Topic

[rcooper]

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.

[Author]

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