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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).
Thank you!
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