[ldoyle]

Our bank has never made HPMLs due to original escrow requirements, however, since we now meet all escrow exemption requirements and we comply with applicable appraisal requirements, are there any potential issues we would need to be aware of if we do start originating HPMLs?

[rcooper]

You are aware of the escrow and appraisal requirements and it seems you meet the small creditor threshold to qualify for the escrow exemption – those are the major pieces for HMPLs.

Are you required to escrow for flood insurance or are you exempt from those escrow requirements?

[ldoyle]

We are not required to escrow for flood insurance since we meet the small lender exception in part 339.5(c)(1). If we should choose to start doing HPMLs, should we address this in our loan or compliance policies and is there anything else we should do?

[Author]

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