ACH origination for loan payment

Posted By: CindyS

ACH origination for loan payment - 11/14/17 09:25 PM

When we originate a monthly ACH to debit a deposit account at another institution for a consumer's real estate loan payment at our institution, what is required to meet the Reg E and NACHA requirements for 10 days notice of change following a payment change due to the annual escrow analysis?

Is the Annual Escrow Analysis statement sufficient, or do we need to include a separate notice of the payment change?