If a borrower has an overage in their escrow - how long do we have to send out their check?

30 days.

To tag on. If you based your intial escrow on the most recent tax information, but the next year's taxes had large credit involved and the bill is going to be much lower than the previous year, if the borrower requests you to send that overage to them....are you required to do that even if your normal analysis wouldn't be due for several more months?

It would depend if you have an escrow agreement and the terms of that agreement.

Absent any agreement you are under no regulatory obligation that I'm aware of to do a short year analysis at the customer's request. The only time I'm aware you are mandated to do the analysis is:

1. The initial analysis
2. Annual analysis
3. Short year analysis after payoff or transfer of servicing

I would opine however that if you do run the short year analysis then you would need to make the payment adjustments and refund the surplus identified by the analysis.


How you want to handle it from a customer service issue is up to you.

Thanks, Dan...what you said is all I can glean out of Reg X. I think it boils down to a customer service issue. If we do a short-year analysis, we will just need to adjust the new annual date.

Thanks for your input!