Can we require a borrower to triple the amount of money that goes into their escrow account?
The Washington DFI released a bulletin this week informing credit unions about a change in Washington law. Beginning June 7, disclosures that comply with RESPA will be considered compliant with the disclosure required under state law.
The case has significant implications for credit unions as it will consider if a consumer can sue in federal court when there is no evidence of actual injury.
Can a credit union require a borrower, who has a less than stellar credit history, to triple the amount of money that goes into the escrow account?