Thanks Dan, sorry for the confusion. I should have identified this appendix as a HUD publication. The section of Respa that you reference refers user to this HUD example. The section of Respa states that "Public Guidance Documents entitled “Annual Escrow Account Disclosure Statement—Format†and “Annual Escrow Account Disclosure Statement—Example†set forth an acceptable format and methodology for conveying this information". These documents can be found at
http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/rmra/res/respagui. So my question is, how closely do we have to follow this guidance? Under our current process, when g3enerating escrow analysis, the new payment effective date could be in the future to allow time for the member to be notified of the change in the escrow payment. Because of this, there may be a difference between the history ending balance under the account history section of the statement and the projections starting balance under projections for coming year, possibly causing customer confusion. Therefore, we would like to add a line of projected activity under the account history section so that the ending and starting balance coincide. We would add a "P" after the projection and footnote this item.
The cause of consternation with this is the statement that "this is a statement of actual activity..." We would like to change this to "this is a statement of activity" but were unclear whether we can deviate from the example.