Anthem
David Curtis
Director, Compliance Services
Phone: 206.340.4785
Toll-free: 800.995.9064 x151
David Curtis is the director of compliance services at the Northwest Credit Union Association. In this role he is responsible for responding to credit union compliance inquiries, informing and instructing credit unions on new compliance responsibilities through updates and council meetings. He is a liaison, facilitator, and presenter at both the compliance and collectors’ networking […]
Will Hall
Director, Legal Advocacy
Phone: 208.297.5877
Toll-free: 800.995.9064 x302
Will Hall serves as the Director of Legal Advocacy for the Northwest Credit Union Association, providing compliance expertise to the Association’s member credit unions, helping them navigate the many compliance challenges they face. After graduating from Davidson College in North Carolina, Hall moved to the nation’s capital, where he worked for several years before attending […]
Compliance Question of the Week
December 10, 2013
Dec. 10, 2013
Can the credit union require a borrower who has a less-than-stellar credit history to triple the amount of money that goes into the escrow account?
Section 17 of RESPA sets limits on the amounts that a lender may require a borrower to put into an escrow account for purposes of paying taxes, hazard insurance and other charges related to the property.
During the course of the loan, RESPA prohibits a lender from charging excessive amounts for the escrow account. Each month, the lender may require a borrower to pay into the escrow account no more than 1/12 of the total of all disbursements payable during the year, plus an amount necessary to pay for any shortage in the account. In addition, the lender may require a cushion, not to exceed an amount equal to 1/6 of the total disbursements for the year.
The lender must perform an escrow-account analysis once during the year and notify the borrower of any shortage. Any excess of $50 or more must be returned to the borrower.
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Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.
Posted in Compliance.