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We have started using an additional line item for our taxes to help HMDA data pull correctly and our Sub Servicer when setting up escrows. When we do this, our CD prints “SOME” in the tax section on page 1. The reg reads that if only a portion of the amounts disclosed will be paid by the creditor, the creditor may use the word “SOME”. My issue is, we are disclosing and escrowing for ALL taxes. Are we at any risk because the CD lists “SOME” and not “YES”?
As you have identified, it appears the disclosure is wrong. The consumer could be mislead by the error.
The additional tax data you are adding seems to be the source of the problem. We suggest discussing this with your loan origination software provider. Either your language or third system need to be adjusted to eliminate the problem.
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