{"id":2944,"date":"2022-12-29T15:57:51","date_gmt":"2022-12-29T15:57:51","guid":{"rendered":"https:\/\/albanknews.com\/?p=2944"},"modified":"2022-12-29T15:57:51","modified_gmt":"2022-12-29T15:57:51","slug":"compliance-qa-respa-and-escrow-accounts","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2944","title":{"rendered":"Compliance Q&A: RESPA and Escrow Accounts"},"content":{"rendered":"

Q. Does RESPA require that we collect a cushion for escrow accounts? How large of a cushion must be collected?<\/b><\/p>\n

A. <\/b>RESPA allows you to have up to 2 months’ cushion in an escrow account but doesn’t *require* that you have 2 months’ cushion.<\/p>\n

“Cushion or reserve (hereafter cushion) means funds that a servicer may require a borrower to pay into an escrow account to cover unanticipated disbursements or disbursements made before the borrower’s payments are available in the account, as limited by \u00a7 1024.17(c).” 12 CFR \u00a7 1024.17 https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1024\/17\/#7c9dd674f7d0217d08f86c841c3a1d971624ad52b89e42ceb2f84935<\/a><\/p>\n

“…In addition, the servicer may add an amount to maintain a cushion no greater than one-sixth (1\/6) of the estimated total annual payments from the account…” 12 CFR \u00a7 1024.17(c)<\/b><\/p>\n

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Compliance Alliance<\/b> offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933<\/b> or email info@compliancealliance.com<\/a> and ask for our Membership Team.<\/p>\n

Sign Up for a live Compliance Alliance demo:<\/b>\u00a0<\/b><\/p>\n