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Compliance Question of the Week
In today’s banking environment as soon as one big new regulation is implemented another pops up. Our compliance resources help your community bank stay one step ahead of the regulators.
Does a bank have to refund an escrow surplus if the borrower is not current?
No. Surplus provisions apply only if the borrower is current at the time of analysis. A borrower is considered current if their payment is less than 30 days past due.
Loan servicers may keep the surplus in the escrow account if the borrower is not current pursuant to the loan terms.
Reference: 12 CFR 1024.17(f)(2)(ii).