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#2254937 - 06/07/21 04:00 PM Failure to Escrow
Comply101 Offline
Junior Member
Joined: Nov 2013
Posts: 26
Our bank recently (almost 2 months ago) closed a loan in a flood zone. We ensured there was enough flood ins. in place prior to closing and provided the required disclosure. Our Closer inadvertently failed to escrow for Flood Ins and the borrower was already intending to escrow for everything else. The lender failed to notice this in their preclosing review and no funds were collected up front to deposit into the escrow acct for Flood Ins. This was only noted when Loan Ops was conducting a review after closing. There was some communication issues with the lender and some time passed but the borrower was made aware and we setup an escrow for flood ins. The lender collected 1 month escrow payment from the borrower since the first payment had already passed by the time we had gotten it all fixed. The escrow account is still several hundred dollars short though since no funds were collected at closing to deposit into that account? Can we ask our borrower to pay this?

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Flood Compliance
#2254942 - 06/07/21 04:08 PM Re: Failure to Escrow Comply101
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
You would have to have completed a short year analysis and then followed the process if there was a deficient balance. You can't just start collecting monies from the borrower.
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