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#2164585 - 02/14/18 10:15 PM Escrow Statements
Baker Offline
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Joined: Nov 2005
Posts: 800
Washington State
The Initial Escrow Disclosure is issued when the loan originates. It covers a 12 month period.

Annually in April the Annual Escrow Analysis Disclosure is prepared and sent in May. If the initial disclosure covers a time period that extends beyond April it appears that the annual analysis is not completed and sent. This could result in a lapse between the initial disclosure and the next annual disclosure.

How should this be handled? If we want to get all loans on the April schedule do we issue a new disclosure for all loans in April of every year?

ex. Loan closes in December 2016, initial disclosure goes through January 2018. An analysis is not completed in April 2017. The next analysis will occur in April of 2018. The borrower will not have any statement covering January 2018-April 2018.

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Lending Compliance
#2164591 - 02/14/18 10:32 PM Re: Escrow Statements Baker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,333
Galveston, TX
Your dates are off, but if you want every loan to cycle in April, you issue a short year statement in April for any loan that has closed since the previous April to get them in sync with the rest of the portfolio. You can't have gaps..
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#2164603 - 02/14/18 11:52 PM Re: Escrow Statements Baker
Baker Offline
Platinum Poster
Joined: Nov 2005
Posts: 800
Washington State
Thanks

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#2164637 - 02/15/18 02:30 PM Re: Escrow Statements Baker
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
Randy's right but I just want to clarify:
You can't have gaps and you can't go more than 12 months without an analysis/annual statement. If your initial Escrow Account Computation Year was Jan 17 - Dec 17 (or Feb 17 - Jan 18) and you want to change it to April, you should have issued a Short Year Statement in April 17. That would have changed the Escrow Account Computation Year to Apr 17-March 18 (or it could be May 17-Apr 18). You can't let it go until Apr 18.
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