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#2090134 - 07/27/16 03:32 PM aggregate adjustment on escrow account
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
I have read somewhere that states the aggregate adjustment should be less than one month's escrow payment. Can anyone point me to the section in the regulation that would address that. I find the aggregate method, but I have figured it twice, and both times, my aggregate adjustment is more than one month's payment.
Thanks in advance for any information.
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Lending Compliance
#2090138 - 07/27/16 03:36 PM Re: aggregate adjustment on escrow account JWills, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,438
Galveston, TX
I'm not sure there is any such rule or statement. Which calculator are you using and what numbers?
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#2090151 - 07/27/16 03:57 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
Randy, I found it in an audit manual. It just states the aggregate adjustment should be less than one month's escrow payment. It doesn't say 'must' and when I read under 1024.17 (d)(2) it doesn't state that either. I am hoping it is just a typo.

I am using a calculator from Compliance Alliance Numbers are
homeowners insurance $833.00 due May 2017
summer property tax $572.44 due July 2016
winter property tax $506.82 due December 2016

First payment starts July 2016.
.
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090159 - 07/27/16 04:29 PM Re: aggregate adjustment on escrow account JWills, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,438
Galveston, TX
I get this using a two month cushion:

1001 Initial deposit for your escrow account $731.80
1002 Homeowner's insurance 3 months @ $69.42 per month $208.25
1004 Property Taxes 8 months @ $89.94 per month $719.51
1007 Aggregate Adjustment -$195.96
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2090210 - 07/27/16 06:17 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
I think the difference I am getting is because the taxes are paid at two different times

Initial deposit $731.80
Homeowners 3 months @ $69.42 per month $208.25
Summer Property Tax 13 months @ $47.70 per month $620.14
Winter Property Tax 8 months @$42.24 per month $337.88

Aggregate adjustment $434.48
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090216 - 07/27/16 06:29 PM Re: aggregate adjustment on escrow account JWills, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
I get the exact same numbers as Randy posted.

We have a free Escrow Analysis Worksheet that you can download form our website:
http://www.bankerscompliance.com/compliance-resources/free-downloads.htm

Simply, right click and "save as" to download it. Instructions are at the bottom of the sheet.

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#2090219 - 07/27/16 06:32 PM Re: aggregate adjustment on escrow account David Dickinson
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,438
Galveston, TX
David - image that. Not saying what method I used to figure out the numbers whistle smile
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2090221 - 07/27/16 06:34 PM Re: aggregate adjustment on escrow account JWills, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,438
Galveston, TX
Summer Property Tax 13 months @ $47.70 per month $620.14

Not sure why you would collect 13 months of payments in the annual analysis.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2090240 - 07/27/16 07:08 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
We are paying the taxes the first month after the loan closes, and then collecting the 13 months for July 2017
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090243 - 07/27/16 07:15 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
Escrow Analysis Calculator - Hazard/Taxes/PMI/Flood
"INSTRUCTIONS: Complete the yellow cells. Hover over the cell to display comments/instructions.
"
RESULTS: The Aggregate Analysis is the numerical information for the Initial Escrow Disclosure. Rows 9 through 17 display the LE/CD disclosure information.
Name(s):
Loan #:
Date: 5/26/2016
1st Loan Pymt: July

Loan Estimate /Closing Disclosure
Line Number (CD) Section G - Initial Escrow Payment at Closing
Initial deposit for your escrow account $731.80
01 Homeowner's insurance 3 months @ $69.42 per month $208.25
02 Mortgage Insurance 0 months @ $0.00 per month $0.00
03 Property Taxes 13 months @ $47.70 per month $620.14
04/05/06/07 Flood Insurance 0 months @ $0.00 per month $0.00
04/05/06/07 City Property Taxes 8 months @ $42.24 per month $337.88
08 Aggregate Adjustment -$434.48
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090244 - 07/27/16 07:16 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
What are we doing incorrectly?
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090270 - 07/27/16 08:54 PM Re: aggregate adjustment on escrow account JWills, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
If you're paying 6 months of taxes in July (the first payment month) and you add 2 months cushion, then that's still only 8 months of taxes in your starting balance. It can't be 13. Then you have 3 months of insurance (1 month needed to start the balance + 2 months cushion). We agree on this number.

The good news is the net initial deposit is the same ($731.80). But for some reason the Compliance Alliance tool you're using is not doing aggregate accounting correctly. I'd show them this string and ask them why.

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#2090319 - 07/28/16 12:45 PM Re: aggregate adjustment on escrow account JWills, CRCM
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,837
The Mitten State
Our loan system is doing it the same way.
We are paying the summer tax in July which is for the entire year,
and then we are paying the winter tax in December which is also for one year. It is not split half and half.
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#2090476 - 07/28/16 08:37 PM Re: aggregate adjustment on escrow account JWills, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
We are paying the summer tax in July which is for the entire year,
and then we are paying the winter tax in December which is also for one year. It is not split half and half.

I'm confused. If you pay ½ the taxes in July and ½ the taxes in December, then they are just for 6 months each. They are both real estate property taxes. You pay them in the summer and winter, but they aren't two different things to escrow separately.

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#2101202 - 09/30/16 03:27 PM Re: aggregate adjustment on escrow account David Dickinson
Cbigun Offline
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Joined: May 2016
Posts: 179
May I bring this back to life? I too am struggling with the Closing disclosure amount we are disclosing but not sure why it is wrong. (I don't know a lot about Escrow, so I apologize)

Home owners Ins = 1035.00 - July
Property tax $1089.46 Paid twice a year Nov/Apr in 544.73 installments
1st Payment October

Used this Analysis tool and come up with these numbers for the closing disclosure:
Initial Escrow at closing - $708.15
Homeowners - $86.25 per month for 4 mo. - $345.00
Property Taxes - $90.79 per month for 7 mo. - $635.52
Aggregate Adj - ($272.37)

We are showing on the Closing Disclosure:
Initial Escrow at closing - 354.08
Homeowners - $86.25 per month for 4 mo. $345.00
Property tax - $90.79 per month for 2 mo. 181.58
Aggregate Adj - (172.50)

Does it matter that the seller is paying the first half? I feel like ours is wrong, I just can't figure out why? Operations says it is right. You guru's know what we are doing wrong? The payments are coming out the same as yours at 177.04 I just can't get the CL to match.

In addition, if you have PMI do you collect a cushion for that or is that up to the bank?

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