I've done a bit more digging and I'm thinking this first escrow statement we are creating in 2018 is a short year statement (we did not change the payment or accounting method). When reading in the federal register, I see language to the effect that "with a transfer, ... Asterisks, inclusion of a copy of the projections issued with the last annual statement, and the paragraph beginning with... are not required of the new servicer."
So, I'm thinking a technical issue to have included something so old but not a violation as it appears our short year statement did not have to have the prior year from the old servicer.
Your thoughts?
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Opinions are mine and subject to change frequently