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Escrow Payment Options

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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?

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.


Learn more about Andy Zavoina’s Annual LENDING Compliance Recap webinar.

First published on 01/10/2021

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