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#2216010 - 06/19/19 02:55 PM Escrow Question - Double Payment
mnbanker09 Offline
100 Club
Joined: Jan 2018
Posts: 122
What actions are required by the Bank when it is discovered that a borrower paid property tax (or insurance) directly and the bank has also paid from escrow? Is there a requirement to issue a refund immediately upon discovery or can we wait for our annual analysis to determine the overage? Any direction to regulation would be helpful!

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Lending Compliance
#2216357 - 06/24/19 09:25 PM Re: Escrow Question - Double Payment mnbanker09
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
There is no requirement to do anything until the next annual analysis. At that time, you'll obviously have a surplus. Alternatively, you could issue a short-year statement and refund the surplus now. Then you could issue another short-year statement at the time of their original anniversary.
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David Dickinson
http://www.bankerscompliance.com

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