Answer:
RESPA’s requirements are strict in that the bank will be able to require “cash in” equal to what it anticipates paying out, plus an allowed cushion. A borrower may make voluntary payments to avoid escrow shock, but likely the bank will end up paying this back to the borrower as an overage unless the taxing authority assesses the new value sooner than expected. The Loan Estimate will note the anticipated tax and insurance costs, but this is a Reg Z disclosure, not the RESPA escrow accrual formula.
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