I’ve personally not had time yet to read through the new Escrow requirements, so hopefully Jack will be going over these in detail in an upcoming Compliance Masters Group, and he may need to weigh in here.
I’m assuming you are referring to the following:
(4) together with its affiliates, not escrow for any mortgage it or its affiliates currently services, except in limited instances.
(taken from Jack’s blog post)
The way I’m reading this at this point, and I think Jack briefly talked about this during last Friday’s Compliance Roundtable session, is that if you are just escrowing when the regulation requires you, then you would meet this exemption criteria. If you escrowed for other loans here and there, it would get to a deeper conversation as to if you and your financial institution meets the criteria to be exempt or not.