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Add CPI Index at Time of Creating Escrow Acct?

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Question: 
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?
Answer: 

Depends on whether or not you know what the actual charge may be. Determining disbursement amount would not very based on initial or an annual statement.

Servicer estimates of disbursement amounts. To conduct an escrow account analysis, the servicer shall estimate the amount of escrow account items to be disbursed. If the servicer knows the charge for an escrow item in the next computation year, then the servicer shall use that amount in estimating disbursement amounts. If the charge is unknown to the servicer, the servicer may base the estimate on the preceding year's charge, or the preceding year's charge as modified by an amount not exceeding the most recent year's change in the national Consumer Price Index for all urban consumers (CPI, all items). In cases of unassessed new construction, the servicer may base an estimate on the assessment of comparable residential property in the market area.

First published on 03/29/2020

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