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Escrow Analysis-Refund if 90 Days Past Due

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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?

If you are referring to an escrow surplus, the rule in Regulation X paragraph 1024.17(f)(2)(i) says that if an escrow analysis discloses a surplus, the servicer must, within 30 days of the date of the analysis, refund the surplus to the borrower if it's $50 or more. However, paragraph 1024.17(f)(2)(ii) says that the requirement for a refund only applies if the borrower's payments are current (no more than 30 days past due).

First published on 04/26/2020

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