1024.17(i)(1) Contents of annual escrow account statement. The annual escrow account statement shall provide an account history, reflecting the activity in the escrow account during the escrow account computation year, and a projection of the activity in the account for the next year. In preparing the statement, the servicer may assume scheduled payments and disbursements will be made for the final 2 months of the escrow account computation year. ...

I can't find any other mention or support for the "final 2 months"- where is it established that the analysis is (or can be) run 2 months prior to the end of the computation year? Can someone give me some context on why you would want to generate the analysis 2 months early?

We're running our analysis early (example, January-December computation year, analysis run October 1) and as a result it's messing up shortage figures when November and December disbursements end up being more than the assumed amount used during analysis. I'm trying to get my head wrapped around whether this is a compliant process. Is there anything stopping us from running the analysis in December or January when you know your final figures?

So, when do you want to run it? November? December? If the new escrow payment amount will be due January 1st, how much lead time do you think you need to give the borrower? If you run it in December, you think 10 days is adequate? Why are your estimates for disbursements in November and December that far off?

Ah, ok, that's the piece I was missing. I wasn't thinking through notice of their new payment amount. Thanks Randy!