Answer:
Neither RESPA nor Reg Z requires a formal agreement, but having a request signed by the borrower is not a bad idea to document how the increased payment came about. RESPA does require the initial statement to be completed within 45 days of the account’s establishment. I recommend doing the analysis and explaining it to the borrower, then collecting the funds and getting Loan Admin to change the billing from P&I to PITI for tax and insurance, assuming those are now included.
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Learn more about Andy Zavoina’s webinar Escrow Accounts A to Z
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