Escrow Discretionary Payments

[Donna Bergeron]

Is anyone in our region servicing consumer escrowed loans and allowing discretionary payments (typical examples of this would be credit life, disability, HOA dues – things that you will be collecting and paying but were not conditions of the loan or traditional escrow items but you will be using the escrow account for collecting and disbursing and therefore the initial and annual escrow analysis statement has to have specific model form language)? We do not but need to assure that if one were to be originated, we could disclose accurately. We are going back and forth with JH and so I was wondering if anyone does them and would be willing to discuss how they do their input in the system. Thank you!

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