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#2178254 - 05/15/18 05:32 PM Construction to Permanent - Escrow
Comply Offline
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Registered: 07/09/15
Posts: 9
​We are working on a new product setup specific to a single closing Construction to Permanent financing mortgage loan. The escrow payments will not begin until the Permanent Financing begins. Are we required to provide the Initial Escrow Account Disclosure Statement at time of closing or when the permanent financing begins or can it be omitted?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2178261 - 05/15/18 05:50 PM Re: Construction to Permanent - Escrow [Re: Comply]
rlcarey Online
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Registered: 07/16/01
Posts: 66452
Loc: Galveston, TX
Since you cannot collect the initial deposit for the escrow account and then just hold it for a year, the escrow would not be reflected on a the CD nor would an initial escrow statement be required. You should be executing a future escrow agreement with the customer that sets forth the requirement to establish the escrow account as the construction portion of the loan is completed. At that time you would provide them with the initial escrow account statement.
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#2179011 - 05/21/18 03:50 PM Re: Construction to Permanent - Escrow [Re: Comply]
Comply Offline
New Poster

Registered: 07/09/15
Posts: 9
Can you help with giving me citations for this detail, for me to reference back to?
We would not show on our disclosures that we are escrowing? Currently our LOS system is showing the escrow amounts on the LE and CD and showing under section G. Our current intent was to collect the initial escrow at closing, and then collect escrow when P&I begins. Is this incorrect?

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