CU Compliance Connection

CFPB Escrow Disclosures

Escrow Closing Disclosure

The Escrow Closing Notice must be provided to a member prior to cancelling their escrow account if an escrow account was established in connection with a closed-end consumer credit transaction secured by a first lien on real property or a dwelling.

Escrow Closing Disclosure

The credit union must provide the notice no later than three business days before the consumer’s escrow account is canceled.

Escrow Closing DisclosureThere are three exceptions to the requirement to provide the notice:

• Reverse mortgage transactions;

• Escrow account was established solely in connection with the consumer’s delinquency or default; and

• When the underlying debt obligation is terminated, including by repayment, refinancing, rescission, and foreclosure.

Escrow Closing DisclosureThe notice must include:

• Closure date;• That an escrow account can be called an

impound or trust account;• Reason for Closure;• That without an escrow account, the member

must pay all property costs;• “Cost to you” Table• “In the future” Table

Escrow Closing Disclosure

The credit union may also disclose:

• The credit union’s name or logo;

• The member’s name, phone number, mailing address and property address;

• The issue date of the notice; and

• The loan number or the member’s account number.

Escrow Closing Disclosure

Thank you for joining me for this review of the Escrow Closing Disclosure

Stay Tuned…

Shawn Wolbert, CIA, CUCEDirector CU System Relations

101 S. Washington Square, Suite 900Lansing, MI 48933-1703(800) 262-6285 Ext. 486(734) 658-5427 MobileFollow me on Twitter – Shawn Wolbert @ Go2CUGuru