[TheBank]

2400.17(f)(1)(ii) states if the bank advances funds to pay an escrow disbursement due to the disbursement being more than the escrow balance, the bank must complete an escrow analysis before seeking repayment of escrow from the borrower. By when must the bank preform an analysis? Does that mean the bank must do an analysis before the next escrow payment from the borrower is made to the bank after the disbursement caused the negative escrow balance? Or does that mean the bank must do an analysis before seeking an increase in the escrow amount to repair the shortage?

[rcooper]

I apologize we overlooked your question earlier. Thanks for your patience.

1024.17(f)(1)(ii) states:
“The servicer may conduct an escrow account analysis at other times during the escrow computation year. If a servicer advances funds in paying a disbursement, which is not the result of a borrower’s payment default under the underlying mortgage document, then the servicer shall conduct an escrow account analysis to determine the extent of the deficiency before seeking repayment of the funds from the borrower under this paragraph (f).”

My understanding is that it would be before you seek an increase as that would be their repayment. Their normal payment would not be repayment of the funds advanced.

[Author]

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