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Effective Dates of Escrow Analysis

Question: 
When completing an escrow analysis, our company's internal audit procedure verifies that the effective date of each analysis is within 12 months. Recently, I reviewed the RESPA guidelines and find that I interpret this differently. The guideline indicates that a servicer must provide an escrow analysis within 30 days of the ending computation from the last analysis. If I understand this, would it be correct in stating that if my last analysis was effective January and ran through December, the subsequent analysis must be completed by January 30 the following year? If this is true, do my effective dates of each analysis have any bearing on this compliance guideline?
Answer: 

If your escrow period ran from Jan.-Dec. of 2002, your escrow statement for that period should be sent by Jan. 30, 2003.

Your next escrow period is Jan.-Dec. 2003 and the statement is due by Jan. 30, 2004.

If the account was paid off in that period, you'd do a short-year statement to close it out.

If you reviewed the account in that period and the account was still open, the short-year statement would establish a new "start date" for your annual statement.

First published on BankersOnline.com 05/3/04

First published on 05/03/2004

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