I am a "rural" bank and as such no longer escrow for 1st lien covered transactions in order to qualify for regulatory exemptions. I have several borrower's who are no happy with the fact that I no longer will escrow. You have taken away their option/right to have this service available to them. Escrow should be available, but not required, to all borrowers if they wish it, not just the distressed borrowers.
Comment on CFPB-2013-0018-0001
This is comment on Proposed Rule
2013 Mortgage Rules under the Equal Credit Opportunity Act, Real Estate Settlement Procedures Act, and the Truth in Lending Act
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