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Escrow Payment Options

Answered by: 

Question: 
We want to offer an option to all escrowed borrowers to lump sum pay any deficiency or shortage. Since it’s optional, it should be OK. Do you agree?
Answer: 

No. The CFPB noted in the Supervisory Highlights that this was a violation. RESPA provides only certain options for different shortage/deficiency conditions and only those are allowed to be offered. Lump sum payments are not always an option.

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First published on 01/10/2021

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