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How to Audit Advertising - Compliance Issues Here, There, Everywhere!;
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Topic Options
#1355492 - 03/10/10 05:06 PM Escrow Set-Up Fee
Nanee Offline
New Poster

Registered: 01/27/04
Posts: 12
Does anyone collect an escrow set-up fee? If so, do you mind to share the amount you collect?

Lending Compliance
#1365823 - 03/29/10 05:23 PM Re: Escrow Set-Up Fee [Re: Nanee]
2Confused2go on Online
100 Club

Registered: 04/24/03
Posts: 146
Loc: Texas
No one seems to be answering questions about escrow fees, either set-up or annual. With the increased cost to the bank, we would like to charge for the service. Does anyone know if it is not allowed for some reason?
- please send any lottery winnings to me!

#1365915 - 03/29/10 08:00 PM Re: Escrow Set-Up Fee [Re: 2Confused2go on]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50412
Loc: Galveston, TX
Whether a fee is allowed or not will all depend on State law. If State law allows, it will be a finance charge and have to be calculated into the APR whether it is a one-time fee or an annual fee.
The opinions expressed are my own, take them or leave them.

#1366492 - 03/30/10 03:10 PM Re: Escrow Set-Up Fee [Re: rlcarey]
CQ1 Offline
New Poster

Registered: 09/21/09
Posts: 16
Loc: GA
We are a Georgia Bank and the GA Dept of Banking and Finance has issued no regulations regarding escrow accounts. I can find nothing in RESPA that refers specifically to a Tax Service Fee or any other "escrow" type one time fee.

Since we are not outsourcing the escrow function, we are considering charging a one-time Tax Service Fee of $75.00 which we know will be included in the APR Calculations and will also affect HOEPA calculations. If we were to outsource the service it would cost us anywhere from $85 - $130 per month, per loan.

Can anyone tell me this type of fee is specifically prohibited?

#1366641 - 03/30/10 05:09 PM Re: Escrow Set-Up Fee [Re: CQ1]
JobSecurity Online
Gold Star

Registered: 10/16/09
Posts: 345
I would like to know if anyone is aware of the rules for the State of Arkansas charging a setup fee.

#1366773 - 03/30/10 10:39 PM Re: Escrow Set-Up Fee [Re: JobSecurity]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50412
Loc: Galveston, TX
CQ1 - if not prohibited by State law - then it is not prohibited.

Deb G - you might want to seek guidance for your State banking association.
The opinions expressed are my own, take them or leave them.


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