Hello All,

I think I have read threads on this subject before and can't find what anything right now.

Loan is not delinquent.

If the borrower was not escrowing and an escrow account was set up as part of lender placed insurance, should we send an initial escrow statement to the borrower as described in §1024.17(g)(1)(ii)

TIME OF SUBMISSION OF INITIAL ESCROW ACCOUNT STATEMENT FOR AN ESCROW ACCOUNT ESTABLISHED AFTER SETTLEMENT. For escrow accounts established after settlement (and which are not a condition of the loan), a servicer shall submit an initial escrow account statement to a borrower within 45 calendar days of the date of establishment of the escrow account.

https://www.consumerfinance.gov/eregulations/1024-17/2015-18239#1024-17-g-1-ii

Yes. You have 45 days after establishing an escrow account to send the initial disclosure. Most send it when establishing the account (not 45 days later).

Thanks Sir