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#2270842 - 05/24/22 08:56 PM ARM Notices/Escrow Notices
Anonymous
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Is it acceptable to send the ARM rate/pymt change notice and the escrow statement notice together?

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#2270847 - 05/24/22 09:14 PM Re: ARM Notices/Escrow Notices Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
You mean in the same envelope?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2270885 - 05/25/22 05:46 PM Re: ARM Notices/Escrow Notices Anonymous
Anonymous
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Yes, 2 separate notices in the same envelope

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#2270889 - 05/25/22 06:30 PM Re: ARM Notices/Escrow Notices Anonymous
Anonymous
Unregistered

I think they would be considered separate because there is no ***continued on next page*** after the ARM Notice leading into the Escrow statement, however all of the pages are number consecutively and not 1-2 and 1-4.

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#2270891 - 05/25/22 07:07 PM Re: ARM Notices/Escrow Notices Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
Official Interpretation
20(d) Initial rate adjustment.

3. Timing and form of initial rate adjustment. The requirement that § 1026.20(d) disclosures be provided in writing, separate and distinct from all other correspondence, means that the initial ARM interest rate adjustment notice must be provided to consumers as a separate document but may, in the case of mailing the disclosure, be in the same envelope with other material and, in the case of emailing the disclosure, be a separate attachment from other attachments in the same email.

1026.20(c) and 1024.17 are silent on the matter.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2270914 - 05/26/22 01:55 PM Re: ARM Notices/Escrow Notices Anonymous
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,531
Bloomington, IN
1024.17(i)

(3) Delivery with other material. The servicer may deliver the annual escrow account statement to the borrower with other statements or materials, including the Substitute 1098, which is provided for Federal income tax purposes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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