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$4.34 tax & $8.68 cushion overstated-corrective action?

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  • April 29, 2019 at 9:51 am EDT #14944
    TheBank
    Participant

    An audit found a TRID loan with overstated annual tax amount by $4.34 and the escrow cushion was overstated by $8.68. The loan originated 10/25/18. We will correct the tax amount to be paid, but what is the best way to correct the cushion/monthly escrow payment? Should we go ahead and conduct an annual analysis to correct the monthly payment of escrow? Would that be considered sufficient with the small overages? Or would more be expected?

    May 3, 2019 at 2:27 pm EDT #15317
    rcooper
    Member

    I apologize we overlooked your question. Waiting until your annual analysis should be sufficient to deal with the surplus. See 1024.17(f)(2).

    May 26, 2019 at 3:23 pm EDT #15570
    jholzknecht
    Keymaster

    Waiting for the annual analysis is sufficient, but you can jump in at any point and do a short cycle to get the payment amount reset and refund the surplus now.

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