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#2118118 - 02/14/17 02:55 PM Escrow statement requirements
gunches Offline
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Joined: Dec 2005
Posts: 210
Our bank does its escrow analysis in June of each year. Can we send both the annual escrow statement and annual analysis out at the same time in June, or does the annual escrow statement need to go out in January?

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Lending Compliance
#2118155 - 02/14/17 04:47 PM Re: Escrow statement requirements gunches
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,630
Bloomington, IN
Annual escrow account statement means a statement containing all of the information set forth in §1024.17(i). As noted in §1024.17(i), a servicer shall submit an annual escrow account statement to the borrower within 30 calendar days of the end of the escrow account computation year, after conducting an escrow account analysis.

(i) Annual escrow account statements. For each escrow account, a servicer shall submit an annual escrow account statement to the borrower within 30 days of the completion of the escrow account computation year. The servicer shall also submit to the borrower the previous year's projection or initial escrow account statement. The servicer shall conduct an escrow account analysis before submitting an annual escrow account statement to the borrower.



Since you do your analysis in June I would assume your computation year would end in July. Sending the Annual Escrow Statement in January would not IMO be compliant with 1024.17(i)
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2118332 - 02/15/17 04:57 PM Re: Escrow statement requirements gunches
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You do the analysis and then send statements showing the history, old projection and new projection based on the analysis. IOW, the analysis leads to the statements. They should be at the same time.
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David Dickinson
http://www.bankerscompliance.com

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#2118333 - 02/15/17 04:58 PM Re: Escrow statement requirements gunches
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If you read the sections on surpluses, shortages, & deficiencies, I think you'll see that you do the analysis and then send statements advising how you are handling the extra or shortfall of funds.
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David Dickinson
http://www.bankerscompliance.com

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