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Do other banks included informational messages on annual escrow statements and is this permitted by Reg X? When looking at Reg X, I don’t see where 1024.17(i) prohibits it. In fact, 1024.17(i)(1) lists the information to include on the statement “at a minimum” which seems to leave room for additional information.
I’d appreciate your thoughts. Thanks!
As you noted, Section 1024.17(I)(1) includes the “at a minimum” comment. Section 1024.17(I)(3) specifically allows the statement to be delivered to the borrower with additional material. One comment seems to allow additional content on the statement, the other seems to allow additional information with the statement. I believe extra caution is needed when the additional content appears on the statement. Make sure the additional information doesn’t obscure the required content of the annual statement.
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