Here’s what’s in the new CFPB FAQ on Escrow Rules



The FAQ clarifies that if the shortfall is equal to or greater than the borrower’s usual monthly escrow payment, it can be addressed with a lump sum, unsolicited lump sum. It also states that since the Real Estate Settlement Procedures Act does not regulate whether a borrower can make an unsolicited payment, this would not be considered a violation of the applicable provision.

“However, the service staff cannot require or provide the option of a lump sum on an annual escrow statement,” the FAQ says. “An annual escrow statement that reflects an analysis of the escrow account may indicate that a deficit may exist or that the borrower may pay the deficit in equal monthly installments over a period of at least 12 months.”


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