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Escrow Analysis Timing

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Are there regs limiting when an annual escrow analysis may be done? We have a borrower that closed in January, first payment due in March, and they received an Annual Escrow Disclosure from our sub-servicer for their payment to change in April. The payment is going up less than $40. Shouldn't this only be conducted at the end of the escrow cycle to determine the shortage/surplus?

RESPA, Reg. X section 1024.17 governs escrow requirements.

Financial institutions will do their analysis on the loan's anniversary date or a set time annually, such as every May. It appears your servicer does theirs at a set time and they did a short year statement to adjust the new loan's analysis date with the portfolio's analysis date.

First published on 06/26/2016

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