According to CFPB’s preliminary list of rural or underserved counties, the county (Delaware, OK) in which my Bank extends 50% of our covered transactions is designated as such. Currently we do have 3 HPML loans in which we escrow. My question is, since we have escrowed for these loans are we now not exempt? These loans were closed after 4/1/10. (Referring to the Compliance Masters Group frontline training under Exemption (D)(1).
The new escrow rules are effective on June 1, 2013. If you bank meets all of the conditions in Section 1026.35(b)(2)(iii) then you may stop escrowing. The fact that you have escrowed on a first-lien HPML does not preclude you from taki advantage of the new exemption.