For single-close construction-permanent loans, if you are not requiring escrows during the construction phase (other than flood insurance, as required) but will during the permanent phase, do you provide the Initial Escrow Account Statement under 1024.17(g) at loan closing or when the loan converts to the permanent phase?

If you provide the Initial Escrow Account Statement at closing, do you also provide a subsequent one at the time the loan converts since you have more definitive numbers at that time?

How can you provide it a closing? How do you know what the charges are going to be a year in advance and of what meaning would it have? You cannot collect the initial escrow deposit until the account is actually established at the time of conversion to the permanent phase of the loan.