Mortgage Servicing Escrow Accts Analysis 2– When does a servicer conduct an escrow account analysis?

Compliance > Regulation X and Z - Servicing
Q:   When does a servicer conduct an escrow account analysis?
 
A:   (UPDATED 6/2/2021): A servicer may conduct an escrow account analysis at any time, but Regulation X requires that the servicer conduct an escrow account analysis before the servicer establishes an escrow account and at the completion of the escrow account computation year in order to provide the borrower with an annual escrow account statement no later than 30 days prior to the end of the escrow computation year. 12 CFR § 1024.17 (c)(2), (c)(3) and (i).
 
 
This Q&A was contained in the CFPB’s Mortgage Servicing FAQs – version 3, as of June 2, 2021 (which may be updated from time to time).  This may be found on the CFPB’s website here:  https://files.consumerfinance.gov/f/documents/cfpb_mortgage-servicing_frequently-asked-questions.pdf
 

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