can you use escrow account surplus to pay overdue late fees? or does it have to be retained in the escrow account?

Thanks!

If it is >= $50 you must refund it to the borrower unless the account is 30 or more days past due at the time of the analysis. Surpluses less than $50 can be left in the escrow account.

You cannot use the surplus to pay accrued late charges.

Thanks!