CFPB TRID Sec. 16.5 - When must the creditor send the Escrow Closing Notice before the escrow account is closed?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  When must the creditor send the Escrow Closing Notice before the escrow account is closed?
 
A:  When the consumer requests cancellation. The creditor or servicer must ensure that the consumer receives the Escrow Closing Notice no later than three business days before the consumer’s escrow account is closed. (§ 1026.20(e)(5)(i))
 
Cancellation for any other reason. The creditor or servicer must ensure that the consumer receives the Escrow Closing Notice no later than 30 business days before consumer’s escrow account is closed. (§ 1026.20(e)(5)(ii))
 
The mailbox rule applies in any case the creditor must send the Escrow Closing Notice. If the notice is not provided to the consumer in person, the consumer is considered to have received the disclosures three business days after they are delivered or placed in the mail. (§ 1026.20(e)(5)(iii))
 
Note:  Business day is given the meaning it has for purposes of providing the Closing Disclosure—i.e., all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a), such as New Year’s Day, the Birthday of Martin Luther King, Jr., Washington’s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day. (See §§ 1026.2(a)(6), 1026.19(f)(1)(ii)(A) and (f)(1)(iii))
 
 
This information can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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