We are looking to designate an address for borrowers to submit notices of error and information requests. Per RESPA we would need to send out an initial communication to inform the borrowers of the address and also ensure the address is disclosed on certain notices/website.

For this initial notice, would a message on a monthly billing statement be sufficient? Or would we need to disclose this on a separate page like a statement stuffer or in it's own mailing? I am trying to give our operations team all the options so that the costs can be considered.

Thanks,

OK, I went back and re-read the official interpretation again:

"A notice establishing an address that a borrower must use to assert an error may be included with a different disclosure, such as a notice of transfer."

I now feel more comfortable making the recommendation that we can satisfy the initial notice of the address by including a message on the monthly billing statement. I guess I answered my own question

Anyone think that would not meet the requirement to inform the borrower of the initial setup of a designated address?

And there doesn't appear to be a prohibition on such a notice in section 1026.41 on the mortgage loan periodic statement. Just ensure you don;t drop it into the wrong part of the form. Review section 1026.41(d) at https://www.bankersonline.com/regulations/12-1026-041#d

Thank you for that reminder John!
Now I hope the bank will decide to take advantage of the designated address...it would really simplify our controls around complying with RESPA.

We are also looking into designating an address under 1024.35(c ). We have already included such address on our periodic statements. Would this suffice both, the initial “written notice” requirement and periodic statement requirement? I would really appreciate the feedback!

Notice of an exclusive address. A notice establishing an address that a borrower must use to assert an error may be included with a different disclosure, such as a notice of transfer. The notice is subject to the clear and conspicuous requirement in § 1024.32(a)(1). If a servicer establishes an address that a borrower must use to assert an error, a servicer must provide that address to the borrower in the following contexts:
i. The written notice designating the specific address, required pursuant to § 1024.35(c) and § 1024.36(b).
ii. Any periodic statement or coupon book required pursuant to 12 CFR 1026.41. [/b][/color]
iii. Any Web site the servicer maintains in connection with the servicing of the loan.
iv. Any notice required pursuant to §§ 1024.39 or .41 that includes contact information for assistance.

Bump