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#22604 - 07/02/02 07:28 PM Initial Escrow Disclosure
CalifDreamin Offline
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CalifDreamin
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Far from Calif
On the initial escrow account disclosure statement, can teh figures be based upon maximums or do you have to use actuals?
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Lending Compliance
#22605 - 07/02/02 07:38 PM Re: Initial Escrow Disclosure
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
24 CFR 3500.17(g)(i) indicates:

The initial escrow account statement shall include the amount of the borrower's monthly mortgage payment and the portion of the monthly payment going into the escrow account and shall itemize the estimated taxes, insurance premiums, and other charges that the servicer reasonably anticipates to be paid from the escrow account during the escrow account computation year and the anticipated isbursement dates of those charges. The initial escrow account statement shall indicate the amount that the servicer selects as a cushion. The statement shall include a trial running balance for the account.

So I would suggest making sure that your amounts are reasonable - whether that would be the maximum amounts (not sure how big of a range you use)- I would leave that judgement to you.
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#22606 - 07/02/02 07:40 PM Re: Initial Escrow Disclosure
Andy_Z Offline
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I am not sure I understand your question. But the escrow statements should reflect what you anticipate paying out and paying in. If you inflate those debits using some theoretical maximum, pay out less for taxes or insurance and end up with an overage, the changes made to the accounting rules would be for naught.

The borrower should be able to compare one statement to the previous and then understand any differences. These should be minimal.

Accuracy is important.
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#22607 - 07/02/02 07:45 PM Re: Initial Escrow Disclosure
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
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Far from Calif
Thank you both for your help. I should have been more clear in what I was asking. But, that is the direction I was going...based upon reading RESPA, I was thinking that #1, if you have actual figures, then you should use them. #2, if you don't have actual figures for the payments and you have to estimate, you can estimate based upon the maximum figures you have seen in that market area.
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#22608 - 07/02/02 08:01 PM Re: Initial Escrow Disclosure
Andy_Z Offline
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I would agree with that but like changing "maximum" to "reasonable based on comparison" as it sounds better.
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My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#22609 - 07/05/02 05:58 PM Re: Initial Escrow Disclosure
Lucy Griffin Offline

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Lucy Griffin
Joined: Nov 2000
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Regulation X doesn't discuss estimates because it doesn't contemplate estimates. You should take steps to know the precise amounts. Particularly if you make the disclosure on the HUD-1, you need real numbers.

However, sometimes things change. Remember that you have 45 days to get out the initial escrow statement. By this time you should have hard numbers. I usually suggest that lenders send this initial notice even if they have used the HUD-1 to disclose the escrow amounts. This way, you have a check point and an opportunity to correct any changes.

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