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#1354711 - 03/09/10 10:08 PM Disclosure of Escrow Payments
Valley Girl Offline
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Joined: Feb 2008
Posts: 142
I just created a test loan for escrow purposes. The early TIL, final TIL and note show the P&I payment amount and do not mention the amount of the escrow payment.

The HUD and Initial Escrow Disclosure Statement do disclose the amount of the "total" payment (PITI). I've been reviewing Reg. Z to determine if the "total" payment must be disclosed on the early TIL and final TIL (included in the payment amount) and haven't been able to put my finger on it.

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Lending Compliance
#1354748 - 03/09/10 10:56 PM Re: Disclosure of Escrow Payments Valley Girl
Cowboys Fan Offline
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Joined: Dec 2002
Posts: 4,615
SC
From the OSC to 226.18 (bold added):
1. Amounts included in repayment schedule. The repayment schedule should reflect all components of the finance charge, not merely the portion attributable to interest. A prepaid finance charge, however, should not be shown in the repayment schedule as a separate payment. The payments may include amounts beyond the amount financed and finance charge. For example, the disclosed payments may, at the creditor's option, reflect certain insurance premiums where the premiums are not part of either the amount financed or the finance charge, as well as real estate escrow amounts such as taxes added to the payment in mortage transactions.

I think the key is "may". I don't recall ever seeing a TIL where the escrowed amount is included in the payment amount, it's normally just the P&I.
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#1354755 - 03/09/10 11:05 PM Re: Disclosure of Escrow Payments Cowboys Fan
Valley Girl Offline
100 Club
Joined: Feb 2008
Posts: 142
Thank you!

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