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#2056176 - 12/30/15 02:48 PM Escrow Closing Notice under 1026.20(e)
Banker 1025 Offline
Junior Member
Joined: Dec 2015
Posts: 28
We are making our way through the new Escrow Closing Notice requirements and I have a question that I cannot find the answer to by reading the Reg or the commentary so I am hoping someone out there can provide some insight as to how their shop is handling this situation. If a borrower requests only one item of their escrow account, for example homeowners' insurance, to be removed from escrow and wants to leave the real estate taxes in the escrow account then: 1. Is the use of the Escrow Closing Notice required? 2. If so, how to complete the notice? We are hesitant to modify model form H-29 in Appendix H to Regulation Z but it would not make sense if the escrow account isn't being closed entirely, just removing one component.
Any thoughts would be appreciated. Thank you!

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Lending Compliance
#2056180 - 12/30/15 02:58 PM Re: Escrow Closing Notice under 1026.20(e) Banker 1025
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,641
Cape Cod
1. No. The notice is required only if the escrow account in total is being closed (with the exceptions for payoff of underlying loan obligation, etc.)
2. See #1.

You certainly can create your own form letter/notice to be used if one element of the escrow account is being terminated (for example, dropping insurance premiums but retaining tax payments).
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#2056345 - 12/31/15 02:05 PM Re: Escrow Closing Notice under 1026.20(e) John Burnett
Banker 1025 Offline
Junior Member
Joined: Dec 2015
Posts: 28
Thank you for the response! TRID has really made us overthink everything we do, we are obviously making things more complicated than we need to.

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