Unless you can predetermine the range of amounts to be debited at the time of getting the authorization, that tactic won't work (and given the nature of tax and insurance escrows, estimating the range is somewhere between slim chance and fat chance).
The requirement, then, is to provide notice when the payment amount will change. I think you can give that notice once, ten days before the first of the new series of payments, rather than before each payment. As for timing, sending the notice with the annual escrow analysis might be smart, since that's when you determine the new escrow payment amount.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8