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Course description

Do you provide escrowing services for the payment of taxes and insurance on consumer real estate loans?   RESPA doesn’t require that you do so… only that you follow strict rules if you do.  However, if your bank makes mortgage loans, you likely escrow for taxes and insurance too.  It makes good banking sense.  Ensuring that consumer borrowers have the funds to pay taxes and insurance isn’t just a helpful customer service – it protects your lien position and collateral.

The business of escrowing for taxes and insurance is a high-stakes endeavor.  Getting it wrong causes consumer harm and potential reputational damage.  Failing to accurately pay taxes when due will cause fines and penalties, and make your bank look inept in its fiduciary capacity.  Failing to accurately disclose escrow items or properly analyze escrow accounts will bring regulatory violations and upset borrowers.  There is a lot on the line!

Escrow rules are numerous.   This webinar will cover them all:

  • RESPA:
    1. Big picture: The difficulty of applying escrowing rules to taxes paid in arrears   
    2. Escrow analysis:  Why, when, and how
      • The escrow account computation year – very important!
      • Allowable figures to use
      • Cushions
      • Calculations
      • Pre-accrual is a big no-no
    3. Payment shock:  why it happens and what can be done about it
    4. Escrow statements: why, when, and how
    5. Escrow balances:  The Goldilocks test:
      • Too much
      • Too little
      • Just right 
    6. Timely escrow payments

 

  • TRID
    1. Escrow’s impact on the LE and CD
      • Sometimes you use math prescribed by TRID rules
      • Sometimes you use math prescribed by RESPA
    2. Aggregate adjustments

 

  • Reg Z
    1. Escrow Closing Notice
    2. HPML Escrow rules

 

  • Flood Insurance
    1. Mandatory escrow rules
    2. Exceptions and exemptions


Join this 2-hour webinar to get the facts you need to know, to be better informed and prepared to manage your escrow compliance program.  All topics will be presented clearly and consisely, from the perspective and real-life experience of a veteran compliance pro (25 years!) who, like you, is currently working in the trenches of her bank as the voice of compliance.

 

WHO SHOULD ATTEND:

Compliance staff, loan administration / production staff, mortgage loan staff, loan officers and audit staff.

 

Instructor(s)

Rebekah Leonard

Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is the Director of Compliance for a $6 Billion community bank in Montana. She has been in the finance and banking industry since 1995, beginning in private-lending before settling into banking, where she's covered nearly all of it - from customer service and teller work, to loan processing and review, to security and business continuity, to ultimately overseeing CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006. She actually likes compliance (really!) and enjoys sharing her passion of it with others.

Course curriculum

  • 1

    Webinar

    • Access Webinar
  • 2

    Materials

    • Slides

    • Annotated LE and CD from CFPB

    • cfpb_mortgage-servicing_frequently-asked-questions_2023-04

    • Sample escrow analysis arithmetic - Appendix E example

    • Section 35 HPML info sheet 2-2023

    • Questions and Answers

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