Have a unique situation where our customer is requesting to escrow both insurance and taxes for their loan. Problem is, there are multiple properties being taken as collateral; meaning there are different homeowner's policies with different expiration dates. Our system does not seem to allow us to add more than one homeowner's policy to the Initial Escrow Statement.

Is there anything in reg that prevents this from being allowed? Or, is there something in reg that would get us in trouble if we put one of the policies under Flood instead?

Sounds like a systems problem to me. Just because there are multiple properties involved in a Section 35 loan does not mean you have to escrow for all of them. Only first liens on a consumer's principal dwelling requires escrows.

Yes sir, these are just investment properties. But the customer is requesting escrow...so, if we can find some way to get our Initial Statement to show it, then it's OK to have both on there?

Why would a bank want to voluntarily take on escrow liability? It will come down to, if you do, you need to do it right.

Yes sir, these are just investment properties. But the customer is requesting escrow...so, if we can find some way to get our Initial Statement to show it, then it's OK to have both on there?

Assuming this loan is a business purpose loan the escrow rules do not apply so there is no requirement under the regulation to provide an initial escrow statement or an annual statement.

How you set up the escrow for in-flow and out-flow is between you and your borrower and any system limitations.