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#2071739 - 03/30/16 09:08 PM Option to Escrow Notice
fungrandma Offline
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Joined: Aug 2015
Posts: 5
At the bottom of the Option to Escrow Notice it says to insert instructions for selecting to Escrow.
What are we suppose to insert? I haven't been able to find anything regarding this.
Help please!

Thank you

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Flood Compliance
#2071747 - 03/30/16 09:35 PM Re: Option to Escrow Notice fungrandma
Compl101TX Offline
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Compl101TX
Joined: Aug 2010
Posts: 378
W. TX
This is what I added:

To choose or decline this option, simply mark the box below with your choice and return this letter in the postage-paid envelope enclosed. If you have any questions about the option to escrow your flood insurance premium, please contact me at...

(checkbox here) I wish to escrow for my flood insurance premium.

(checkbox here) I decline the option to escrow for flood insurance.
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#2071757 - 03/30/16 11:54 PM Re: Option to Escrow Notice fungrandma
Lakeminded Offline
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Joined: Mar 2014
Posts: 76
Washington
We were going to give them instructions to call either the local or toll free number, but now I'm concerned that we should provide a mailing address due to the limitation of support hours. I couldn't find anything in the training materials that would provide me guidance. Does anyone have any concerns if we only provide phone numbers as our way of instructing the borrowers?
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#2071775 - 03/31/16 01:16 PM Re: Option to Escrow Notice fungrandma
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
ยง339.5(d)(2) [the FDIC's version] states:
(2) Notice. For any loan subject to paragraph (d) of this section, the FDIC-supervised institution, or a servicer acting on its behalf, shall mail or deliver to the borrower no later than June 30, 2016, or September 30 of the first calendar year in which the FDIC-supervised institution has had a change in status pursuant to paragraph (c)(2) of this section, a notice in writing, or if the borrower agrees, electronically, informing the borrower of the option to escrow all premiums and fees for any required flood insurance and the method(s) by which the borrower may request the escrow, using language similar to the model clause in appendix B.

The model clause in App B finishes with this:
To choose this option, follow the instructions below. If you have any questions about the option, contact [Insert Name of Lender or Servicer] at [Insert Contact Information].
[Insert Instructions for Selecting to Escrow]


The regulators left the options open and dictate a specific way it had to be done. It doesn't say the borrower has to check a box, call, not call, etc. I think providing a phone number is fine Lakeminded. For instance, you could say "If you have any questions about this option or to opt-in, please call xxx". I think the method Compl101TX illustrates is also fine.

Our clients are telling us that very few, if any, are opting in to the escrow. VERY few.
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David Dickinson
http://www.bankerscompliance.com

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#2071789 - 03/31/16 02:08 PM Re: Option to Escrow Notice fungrandma
fungrandma Offline
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Joined: Aug 2015
Posts: 5
Thank you for the information.

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#2071939 - 03/31/16 07:15 PM Re: Option to Escrow Notice fungrandma
Compl101TX Offline
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Compl101TX
Joined: Aug 2010
Posts: 378
W. TX
"Our clients are telling us that very few, if any, are opting in to the escrow. VERY few."

I only sent out a few letters, out of those few only one customer stated that he did not want to escrow. Must people want to cancel the escrow account as soon as they can.
_________________________
My opinion only.
AVP-Compliance

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#2076611 - 05/02/16 05:42 PM Re: Option to Escrow Notice Compl101TX
lds1958 Offline
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Joined: Oct 2006
Posts: 508
Are we required to send the letters certified mail, return receipt requested?

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#2076618 - 05/02/16 06:20 PM Re: Option to Escrow Notice fungrandma
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
No such requirement exists.
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David Dickinson
http://www.bankerscompliance.com

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#2076632 - 05/02/16 07:00 PM Re: Option to Escrow Notice David Dickinson
lds1958 Offline
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Joined: Oct 2006
Posts: 508
Thanks David!

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#2077298 - 05/05/16 07:15 PM Re: Option to Escrow Notice fungrandma
George Offline
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Joined: Apr 2016
Posts: 364
Even though the notice isn't required to be returned, is it wise to add a signature line for added verification? Or is that over-kill?

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#2077309 - 05/05/16 07:41 PM Re: Option to Escrow Notice fungrandma
burke116 Offline
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Joined: Jun 2014
Posts: 542
RVA
Definite overkill.

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#2077401 - 05/06/16 03:05 PM Re: Option to Escrow Notice fungrandma
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Agree it's overkill.
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David Dickinson
http://www.bankerscompliance.com

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