Synergy by Association
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT

Compliance Alliance Question of the Week

4/16/2019

 
Question:
We escrow for taxes and insurance. This is not an HPML loan nor is flood insurance required in this situation. The taxes, with respect to this loan, are subject to a continual homestead credit that exceeds the tax charge. So, year after year, the amount via escrow that is owed is $0.00. The bank would like to collect a small amount as a cushion in case the taxes increase over the established credit. We don’t necessarily anticipate the taxes to increase, though. Can we do this?
 
Answer:
12 CFR 1024.17(c)(ii): https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1024/17/#c-1-ii  - (1) A lender or servicer (hereafter servicer) shall not require a borrower to deposit into any escrow account, created in connection with a federally related mortgage loan, more than the following amounts:
(ii) Charges during the life of the escrow account. Throughout the life of an escrow account, the servicer may charge the borrower a monthly sum equal to one-twelfth (1/12) of the total annual escrow payments which the servicer reasonably anticipates paying from the account. In addition, the servicer may add an amount to maintain a cushion no greater than one-sixth (1/6) of the estimated total annual payments from the account.

Comments are closed.
    Picture

    Archives

    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    October 2019
    September 2019
    August 2019
    July 2019
    June 2019
    May 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    September 2018
    August 2018
    July 2018
    June 2018
    May 2018

    Categories

    All
    Compliance

    RSS Feed

    Compliance Alliance offers a comprehensive suite of compliance management solutions.

    To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Copyright © 2023 Synergy by Association, Inc.  All Rights Reserved.
1149 Court Street NE  |  PO Box 13429  |  Salem, OR 97309  |  (800) 468-8558
Picture