Monthly Archive:: November 2018

Compliance Question of the Week

Question: HELOCs and escrow for flood–are they always exempt even if in 1st position? Answer: Yes, that’s correct–there’s a specific exemption for HELOCs in and of themselves: 339.5   Escrow requirement. (a) In general—(1) Applicability. Except as provided in paragraphs (a)(2) or (c) of this section, an ...Read More