I'm curious as to how others handle sending out an initial escrow account disclosure at the creation of an escrow account for forced placed insurance. Our servicing vendor only has the option to either always send out an initial escrow account disclosure or nothing at all with all new loans that are set up on our system. We currently today provide an initial escrow account statement at closing so I don't really like the idea that our vendor would send out another one as I think it's a poor customer experience plus I personally prefer to have it provided at closing.

Currently our process is to also generate an escrow analysis because when an account is set up due to force placed insurance, the consumer doesn't send in a check to establish the starting balance that is reflected on the initial escrow account statement. I know the regulation states that an initial escrow account statement is required when an escrow account is established, but does any one know what the regulators would think if we were to only send the escrow analysis that reflects their shortage, new payment, etc. ?

Thanks!