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.
Make sure those Affiliated Business Arrangements are not a sham.
I found this interesting. Is this not the issue Dodd/Frank is trying to address in making financial institutions responsible for their 3rd party vendors? It seems if or when it gets tested in the courts, there will be precedent in this case.