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#2034583 - 08/19/15 06:00 PM Est tax, ins, assess -escrow for flood but not hoi
SaaL Offline
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Joined: Mar 2008
Posts: 294
The Texas Hill Country
For projected payments on the LE under estimated tax, ins, assessments - I can anticipate a scenario where after 1/1/16 we might escrow for flood (mandatory under B/W, HFIAA) but not homeowner's insurance. In the Projected Payments table, would we show the insurance amount as "in escrow" yes? or no?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2034587 - 08/19/15 06:11 PM Re: Est tax, ins, assess -escrow for flood but not hoi SaaL
Island Dreaming Offline
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Joined: May 2009
Posts: 231
midwest
From the official commentary to 1026.37(c)(4)(iv):
2. Amounts paid by the creditor using escrow account funds. Section 1026.37(c)(4)(iv) requires the creditor to disclose an indication of whether the amounts disclosed pursuant to § 1026.37(c)(4)(ii) will be paid by the creditor using escrow account funds. If the amount disclosed pursuant to § 1026.37(c)(4)(ii) requires the creditor to disclose a description of more than one amount and only some of those amounts will be paid by the creditor using escrow account funds, the creditor may indicate that only some of those amounts will be paid using escrow account funds, such as by using the word “some.”
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#2034588 - 08/19/15 06:13 PM Re: Est tax, ins, assess -escrow for flood but not hoi SaaL
Jerod Moyer Offline
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Jerod Moyer
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
In the case of a scenario where you anticipate having to escrow for flood insurance but will not escrow for hazard insurance the Projected Payment Section would indicate "Homeowner's Insurance" "In Escrow?" "Some". Check out the §1026.37(c)(4) and Commentary to §1026.37(c)(4)(iv) #2 for further details.
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Jerod Moyer
www.bankerscompliance.com

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#2034591 - 08/19/15 06:18 PM Re: Est tax, ins, assess -escrow for flood but not hoi SaaL
SaaL Offline
Gold Star
Joined: Mar 2008
Posts: 294
The Texas Hill Country
Perfect! I skipped over that in the commentary but I see it now. Thanks!
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#2061306 - 01/29/16 07:21 PM Re: Est tax, ins, assess -escrow for flood but not hoi SaaL
MonicaMc Offline
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MonicaMc
Joined: Dec 2013
Posts: 238
Land of Oz
Digging up this old thread....

I looked through 1026.37(c)(4) and found this:
To provide clarity and to ease compliance burden, the Bureau is adopting comment 37(c)(4)(iv)-2, which provides that if the amount disclosed pursuant to § 1026.37(c)(4)(ii) requires the creditor to disclose a description of more than one amount other than amounts for payments of property taxes or homeowner's insurance and only some of those amounts will be paid by the creditor using escrow account funds, the creditor may indicate that only some of those amounts will be paid using escrow account funds, such as by using the word “some.”

So if we are escrowing Flood Ins, but NOT escrowing Hazard Ins, then it will still say "YES" and not "SOME". The only time it would say "SOME" is if we were escrowing for say HOA dues, but not for the monthly mailbox fee.

Correct?

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