ATTENTION ONLINE CREDIT UNIONS
This morning (Feb 23, 2023) we made some adjustments to the layout and verbiage on escrow analysis statements, to address several issues brought to our attention by clients. Specifically:
- Based on a CFPB interpretation of a section of RESPA, we have removed all references to making a “lump sum” payment of an escrow shortage amount. According to this interpretation, it’s a permitted repayment option, but it cannot be required under Reg X, and therefore cannot be included on the disclosures.
- As a result of this change, we were able to correct some over the overprinting issues in the payment breakdown columns. There are no longer “option 1” and “option 2” columns so there is more room for the headings.
- The verbiage on the payment coupon was altered to remove a suggested lump sum payment amount.
- We also corrected a printing error at the top of the statement where a long credit union name was overprinting the report name and page number.
Attached is a mockup of the new statement layout with the changed areas marked.
