06/27/2021
We normally perform escrow analysis annually each year in January on all our escrowed loans. It is now February and we realized this was not done. Doing the analysis now, a month later - will this affect anything adversely? We usually give the customers notice 60 days before changing their payments which was usually in March. Assuming we need to wait now until April. Will this affect them in anyway having a 13 month cycle now versus what would normally be a 12 month analysis time frame? And then next year should we keep the analysis in Feb or go back to January which would result in a short 11 month cycle next year?
05/30/2021
If an interest rate adjustment occurs on the mortgage at the same time escrow analysis is completed, can these notices be combined?
Should the payment change date on the table for the Interest Rate Adjustment reflect the payment change for escrow analysis if that date is before the date the payment changes for the interest rate? Ex. Rate changes May 1st. Payment would change June 1st, but the payment also changes May 1st for escrow analysis. The table shows payment change for May 1st.
06/07/2020
Can the Annual Escrow Statement be provided to the borrower using an e-statement or must a paper copy be snail mailed to borrower?
05/31/2020
If a loan is delinquent for more than 30 days and the annual escrow statement is not sent, can the annual analysis still be ran and if the loan is re-instated, the history provided at that time? To clarify, still run the annual analysis and provide all if the account is re-instated when the annual statement being provided is resumed.
04/26/2020
Is there a rule on escrow analysis's that if the loan shows getting a refund, and it's 90 days past due that we don't have to issue the escrow refund?
04/12/2020
Our bank escrows and when the loan is a Higher Priced Mortgage Loan (HPML) we do escrow for taxes and insurance including flood insurance if in place. When a loan is not an HPML and the customer does want to escrow, is it acceptable to escrow just for taxes? Our borrower requested this as they do not want to escrow for their homeowner's insurance. I have reviewed 1024.17 - the escrow will be added to the loan documents and disclosures provided - so it will not be under the borrower's total control. I just wanted to verify that we should escrow for both taxes and insurance in this situation, even if escrow is not required.
03/29/2020
After watching an escrow webinar my bank decided to no longer add the 3% to the premium amount on the closing disclosure. Since the webinar, I have forgotten and did not properly document why. Can you please confirm or advise me on the initial escrow statement, per regulation, if we can add this? I recall it was created from the CPI Index. I understood this could be added at the annual escrow analysis, but NOT on the closing disclosure or Initial Escrow Statement/Disclosure. Is that right, or can we add the CPI index at the time of creating the escrow account?
03/29/2020
After watching an escrow webinar my bank decided to no longer add the 3% to the premium amount on the closing disclosure. Since the webinar, I have forgotten and did not properly document why. Can you please confirm or advise me on the initial escrow statement, per regulation, if we can add this? I recall it was created from the CPI Index. I understood this could be added at the annual escrow analysis, but NOT on the closing disclosure or Initial Escrow Statement/Disclosure. Is that right, or can we add the CPI index at the time of creating the escrow account?
01/05/2020
There is a surplus in the borrower's escrow account, but the loan is past due. Can we apply this surplus to his loan? The surplus is $315.44 due to
decrease in his homeowner's insurance premium.
11/24/2019
Are there any regulatory requirements that a bank must pay interest on escrowed funds? This would be borrowers funds held for construction not tax
and insurances.
