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#2197541 - 11/07/18 08:52 AM PMI on Periodic Statement
ComplyCycle Offline
100 Club

Registered: 12/17/14
Posts: 202
On the revised closed-end periodic statement, are most institutions including PMI payments in the "escrow" section in both the "Explanation of Amount Due" and "Past Payment Breakdown" sections?

Section 1026.41(d)(2) and (3) require us to provide a breakdown showing how much was applied to escrow, but this is causing borrower confusion since PMI is not included in the borrower's escrow account. It's my belief that PMI should remain on the statement in the "escrow" totals, but I'm curious what others think, please.

Thank you.


Edited by ComplyCycle (11/07/18 11:37 AM)
Edit Reason: Clarified citation per post below

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#2197561 - 11/07/18 10:20 AM Re: PMI on Periodic Statement [Re: ComplyCycle]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 45141
Loc: Bloomington, IN
I think you may be referring to 1026.41(d)(2) & (3).

How is the required monthly PMI payment not included in the escrow account? It may be a direct passthrough payment but it still processes through the escrow account.

Escrow account means any account that a servicer establishes or controls on behalf of a borrower to pay taxes, insurance premiums (including flood insurance), or other charges with respect to a federally related mortgage loan, including charges that the borrower and servicer have voluntarily agreed that the servicer should collect and pay. The definition encompasses any account established for this purpose, including a “trust account”, “reserve account”, “impound account”, or other term in different localities. An “escrow account” includes any arrangement where the servicer adds a portion of the borrower's payments to principal and subsequently deducts from principal the disbursements for escrow account items. For purposes of this section, the term “escrow account” excludes any account that is under the borrower's total control.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2197582 - 11/07/18 11:38 AM Re: PMI on Periodic Statement [Re: ComplyCycle]
ComplyCycle Offline
100 Club

Registered: 12/17/14
Posts: 202
Thanks for the quick response; I agree that PMI should be included on the periodic statement since it is part of the borrower's escrow account as a direct pass-through.

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