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#2247759 - 01/15/21 08:35 PM Billing Notice on Escrow Loans
Lori Offline
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Joined: Oct 2018
Posts: 29
If an Escrow Loan is on AFT or ACH, do we still have to send a billing notice to customer? We do not send an AFT or ACH notice each month.

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Escrows on Higher-Priced Mortgages
#2247760 - 01/15/21 08:41 PM Re: Billing Notice on Escrow Loans Lori
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 75,540
Galveston, TX
What is an escrow loan? If you are required to send periodic statements on a mortgage loan - the loan being on automatic payment is irrelevant.
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#2247761 - 01/15/21 09:21 PM Re: Billing Notice on Escrow Loans Lori
Lori Offline
Junior Member
Joined: Oct 2018
Posts: 29
Sorry yes its a Mortgage loan with Escrow. So am I understanding right, that you are saying all mortgage loans have to have a monthly billing notice or coupon book, even if its set on AFT or ACH for payment? Does not matter if its a Mortgage loan with/without Escrow

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#2247762 - 01/15/21 09:35 PM Re: Billing Notice on Escrow Loans Lori
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 75,540
Galveston, TX
Unless you are a small servicer and exempt from 1026.41, I see no exemption just because a loan is on automatic payments. I am confused as to why having an escrow account or not having an escrow account has anything to do with the periodic statement requirements?
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#2248057 - 01/22/21 10:16 PM Re: Billing Notice on Escrow Loans Lori
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,196
On the Net
Lori, are you referencing purely a payment receipt and asking if it differs based on ACH or auto fund transfer and if that differs based on the loan using an escrow feature? Have you reviewed 1026.41 (https://www.bankersonline.com/regulations/12-1026-041) or might this be some state issue?

Escrows influence content as to payments coming due but I'm unaware where receipts are required because there is an escrow.
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