Vendor Guru Q&A - Lending

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Latest Lending - Escrow Topics

Letter Concerning an Escrow Overage?

11/04/2018

Is there suggested text for a letter concerning an escrow overage?

Transfer of Service on a Fannie Mae Loan

07/15/2018

We are in the middle of completing a transfer of servicing on a Fannie Mae loan in our portfolio. Fannie Mae owns this loan, and we are just transferring the servicing and the escrow account that we hold. Since we are closing the escrow account here, it's my understanding that we need to send the Escrow Closing Notice required in 1026.20. I am getting some push back on this from Fannie Mae - saying that they have never heard of this and they do not agree due to the model language in the letter. I agree that it seems confusing - but we do not transfer mortgages ever so I want to make sure that we have everything correct. Can you provide any clarity on this situation? Should we be sending the Escrow Account Closing Letter?

Aggregate Adjustment for Escrow-Closing Disclosure

06/17/2018

If the seller is paying all the closing costs, does the aggregate adjust for the escrow show as a credit to the seller or buyer on the closing disclosure?

Continue Escrow Tax/Insurance if Stopped Payments

03/11/2018

Does a bank have to continue to make escrow taxes and insurance on behalf of borrower when they have stopped making their monthly payments? In other words, they are about to be in default?

Taxes/Insurance Description on Escrow Analysis

02/04/2018

Can someone clarify for me what description goes on the annual escrow analysis - the term "Taxes" or "Insurance" - or should it be the actual payee such as "State Farm" and where I can find that in the regulation? What I have found implies you could use either.

Closing an escrow account

08/27/2017

Can a bank choose to close an escrow because they no longer want to routinely escrow?

Escrow closing notices

08/20/2017

If a customer has an escrow account set up for taxes and insurance and they call and request to remove the insurance portion but keep the taxes do you need to send an escrow closing notice for the insurance portion that is being removed?

Lowering Escrow Payment: Run Short Year Analysis?

05/28/2017

If we are lowering an escrow payment due to a reduction in the monthly PMI payment or say the flood insurance is no longer required and the customer no longer want to escrow for it. Do we need to run a short year analysis or can we just lower the payment by the amount of the monthly decrease and notify the customer in writing?

Standard Payment Posting Order for Escrow Loan

05/28/2017

For a loan with escrow, what should the standard payment posting order be, and should the loan docs specify which escrow items get contributions in what order?

Deceased Customers with Outstanding Loans

03/26/2017

When a borrower is deceased, family members continue to make payment and the account has an escrow account: 1. Is the bank still obligated to continue paying taxes and insurance from the escrow account? 2. If the loan has PMI does the company need to be notified? If the loan does not have an escrow account: 1. If the loan payments are still being paid by a family member and the insurance is being paid but left in the deceased person's name, what avenue should the bank take?

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New from CFPB: Escrow Accounts - and More

The rules are finally coming to implement the Dodd-Frank Act compliance changes. The big one - the rule to merge RESPA and TILA mortgage disclosures - won't be out until August.

Flood Insurance: A Tidal Wave of Changes

While everyone was worrying about mortgage lending reform, Congress slipped through some significant changes to flood insurance requirements.

Number of Key Fields for HMDA Data Fields

11/18/2018

HMDA - Number of key fields - Out of the 110 data fields, I need to verify the number of key fields for the HMDA Data Fields. I think that the number is 37 but I just want to be certain.

Advertisement for Finance Offer-Trigger Terms

11/18/2018

I am new to lending compliance and have an advertising question. My bank wants to advertise the following: "Enjoy our special 20-year financing offer. Ask us for details." I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees because an interest rate is not quoted. Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both terms assuming this is a trigger term?

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