Two risky strategies of the past - high-cost home equity loans made without tax and insurance escrow accounts, and the use of tech platforms siloed between different types of real estate lending - are coming back to bite mortgage lenders via tough new regulations.

On April 1, 2010, a much wider swath of loans, including hundreds of billions of dollars in new home equity loans, will be required by changes in the Truth in Lending Act's Regulation Z to carry escrow accounts, a measure many institutions are not prepared for from a systems perspective.

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