One thing leads to another and all, and I have a question that touches on different topics that I can't seem to find a good answer.

A customer has an HPML that requires an escrow account. The customer made a loan payment that was exactly sufficient to cover P&I with nothing towards escrow.

The system didn't roll the due date, assessed a late charge, and reported the loan late.

We're learning of this a number of months after the fact. It appears that the customer did not have a payment coupon, inquired about the payment at the teller line, and was quoted the payment without the escrow.

We believe that the right thing to do in this case is to refund the late charge, correct the customer's bureau, and be certain the current due date is actually correct. But, is that necessary? Are we being too cautious in this case? We've looked and can't find anything definitive to steer us in the right direction and more importantly we need to convince a decision maker if the correction, etc. is the right course of action.

Thank you in advance for any advice or any tips on where to find the answer to this question.

Look at your loan contract. Most likely the loan agreement only calls for P&I payments. I don't ever recall reporting a loan past due because of the escrow payment being short.

I would agree that the credit history should be corrected.