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A borrower with an HPML moves to a new state and requests to add flood insurance to their existing escrow account. The annual flood premium is $1,200. How should this be handled?

Correct Answer

B) Add flood insurance to escrow and adjust monthly payments accordingly

Under TILA Section 1026.35(b)(1), HPML escrow accounts must include property taxes and insurance. Flood insurance, when required, is considered insurance that must be included in the escrow account. The servicer should add it and adjust monthly payments with proper notice under RESPA requirements.

Answer Options
A
Require the borrower to pay flood insurance separately since it wasn't in the original escrow
B
Add flood insurance to escrow and adjust monthly payments accordingly
C
Flood insurance cannot be escrowed for HPMLs due to regulatory restrictions
D
Require a new escrow analysis and 60-day notice before implementing changes

Why This Is the Correct Answer

Under TILA Section 1026.35(b)(1), HPML escrow accounts must include property taxes and insurance. Flood insurance, when required, is considered insurance that must be included in the escrow account. The servicer should add it and adjust monthly payments with proper notice under RESPA requirements.

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