This may have a significant effect on the title business –
CFPB Finalizes Procedures for Supervising Nonbanks Engaged in Risky Conduct| Ballard Spahr.
This may have a significant effect on the title business –
CFPB Finalizes Procedures for Supervising Nonbanks Engaged in Risky Conduct| Ballard Spahr.
On June 1, 2013, the Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which requires certain creditors to create escrow accounts for a minimum of 5 years for higher-priced mortgage loans (HPMLs). The rule exempts HPMLs made by certain small creditors that operate predominantly in rural or underserved counties from this requirement. There are no exempt counties in New Jersey but our neighbors in New York and Pennsylvania have counties that made the list. Check this article on the CFPB website and download the entire list of counties.
Final list of rural and underserved counties for use in 2013 > Consumer Financial Protection Bureau.
This article is a good summary what you need to ask yourself if there is a chance of a RESPA violation. The article comes from Raealtor Mag