Servicing of loans is being transferred to our bank from a loan servicer. The loan servicer is completing a short-year statement as required by § 1024.17(i)(4)(ii).
Short year statement upon servicing transfer. Upon the transfer of servicing, the transferor (old) servicer shall submit a short year statement to the borrower within 60 days of the effective date of transfer.
As per 1024.17(e)(1), we would be required to send an initial escrow statement upon the transfer of servicing if the monthly payment amount or the accounting method used was changing.
We as the new servicer are not changing the monthly payment amount or the accounting method used by the old servicer. Are we required to send our any type of escrow statements to the borrower at the time of transfer? When the old servicer provides the short-year statement to the borrowers, if there are any surplus or deficient balances, would the new servicer have to account for that and ensure compliance with shortages, surpluses and deficiencies? I could not find anything in RESPA to specifically address this but I could be missing it.