How do you get around the already existing pending new escrow payment? When we run them with a pending payment already existing, our escrow payments no longer match the bills and when they pay current the
payment split goes crazy as the bills and escrow payment don’t match. Any information will be helpful as this manual process is difficult for us. Thank you.
Tami Ozogar |
Loan Operation unit manager
3152 NYS Route 417; Olean, NY 14760
P: (716 ) 376-7270
cbna.com
From: xxxxxx@marug.simplelists.com <xxxxxx@marug.simplelists.com>
On Behalf Of Andrea Niedzwicki
Sent: Tuesday, July 30, 2024 1:17 PM
To: xxxxxx@marug.simplelists.com
Subject: SilverLake MA-RUG RE: Escrow analysis question
Good afternoon, Even though you are exempt (per the below reg), we choose to run an escrow analysis on past due loans, those in Foreclosure and in Bankruptcy. For
loans in Bankrupcty, when the escrow analsyis is performed, we send the escrow
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Good afternoon,
Even though you are exempt (per the below reg), we choose to run an escrow analysis on past due loans, those in Foreclosure and in Bankruptcy. For loans in Bankrupcty,
when the escrow analsyis is performed, we send the escrow analysis statement to our attorney so they can prepare the Notice of Payment change and send it to the borrower’s counsel.
If you have any other questions let me know.
Thank you,
Andrea Niedzwicki
Assistant Vice President
Collections Manager
NMLS #712809
Rosedale Federal Savings & Loan Association
9616 A Belair Road
Baltimore, MD 21236
(p) 410-668-4400 ext.344
(f) 410-497-7990
From: Tami Ozogar - Tami.Ozogar at cbna.com (via silverlake list) <xxxxxx@marug.simplelists.com>
Sent: Tuesday, July 30, 2024 9:14 AM
To: xxxxxx@marug.simplelists.com
Subject: SilverLake MA-RUG Escrow analysis question
Good morning,
Can anyone tell me how they are handling escrow analysis on accounts that are past due and already have a pending payment? In the past we have been audited by the CFPB, OCC and HUD and it has been stated
to us that even though you are exempt from sending an escrow analysis statement, you are still required to provide the customer notification of any deficiency that exists in their escrow account each year. This has become very cumbersome and manual for us.
For Bankruptcy loans, we have to strip all of the escrow payments and escrow billing records off the system, create a spreadsheet of these bills, deposit total funds for escrow in bills being stripped out, add a fee record for this deposit amount and then
run the analysis. Collections has to manual split the payments that might come in until loan becomes current. For non-bk loans, we have to run a trial and manually analyze the account to determine if there is a shortfall and then create a deficiency letter
if one exists to the customer. Any other suggestions would be greatly appreciated. Thank you.
ยง
1024.17 Escrow accounts. | Consumer Financial Protection Bureau (consumerfinance.gov)
Tami Ozogar |
Loan Operation unit manager
3152 NYS Route 417; Olean, NY 14760
P: (716 ) 376-7270
cbna.com
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