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2022: What You Need to Know About Escrows

This program provides comprehensive coverage of flood regulations, Regulation X, and Regulation Z escrow rules. We explain, step-by-step, how to establish, maintain, and cancel escrow accounts under the amended requirements. In addition, suggestions for avoiding violations and penalties are provided.

OnDemand
Recorded Wednesday,
July 13th, 2022
Presented by Jack Holzknecht
2h total length
2.5 CRCM Credits
$279.00 or 1 Token

Includes: 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Compliance
  • Lending
  • Risk Management/Legal
  • Bank Legal Counsel
  • Compliance Officer
  • Internal Auditor
  • Loan Closer
  • Loan Operations Manager/Specialist
  • Mortgage Lender
  • Risk Manager
  • Trainer

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The Real Estate Settlement Procedures Act (Regulation X) has contained rules for administering escrow accounts for many years. Both the Truth in Lending Act (Regulation Z) and the interagency flood regulations contain provisions that require escrows in connection with certain loans. The Real Estate Settlement Procedures Act and Regulation X have requirements for establishing and maintaining escrow accounts. We will explain how those rules are changing.

Higher-Priced Mortgage Loans - On January 19, 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs).

It exempts from the HPML escrow requirement any loan made by an insured depository institution or insured credit union and secured by a first lien on the principal dwelling of a consumer if
  • The institution has assets of $10 billion or less;
  • The institution and its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year; and
  • Certain of the existing HPML escrow exemption criteria are met.

Flood Insurance Frequently Asked Questions - On May 11, 2022, the Board of Governors of the Federal Reserve System, the Farm Credit Administration, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (jointly, the agencies) issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. The Q & As address a number of flood related topics including escrow rules. The revised Q & As were effective upon publication

This webinar covers all of the escrow rules, including the long standing and the recently revised requirements of the flood regulations, Regulation X and Regulation Z.

What You'll Learn

  • Which loans are required by Regulation Z and the flood regulations to have escrow accounts, and which are exempt;
  • The limitations on the amount of the required escrow payments at origination and over the life of the loan;
  • How to conduct an escrow analysis;
  • How to determine an escrow account computation year;
  • The rules for preparing the initial escrow account disclosure statement;
  • The TRID rules regarding the escrow notices required in the Closing Disclosure;
  • The expanded Flood Hazard Notice for Escrow information;
  • The flood insurance option to escrow notice;
  • How to prepare the annual escrow account statement;
  • How to resolve a surplus, a deficiency or a shortage;
  • Regulation X rules for timely escrow payments and treatment of escrow balances;
  • Regulation Z rules regarding escrow cancellation notices;
  • The recordkeeping rules for escrow accounts;
  • The penalties for the failure to submit an initial or annual escrow account statement; and
  • The revisions to the Regulation Z rules made by the EGRRCPA

Who Should Attend

The program is designed for compliance officers, operations personnel, mortgage loan officers, loan originators and others involved in opening and maintaining escrow accounts for mortgage loans.


Jack Holzknecht

Instructor Bio

Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 44 years. In 39 years as a trainer over 147,000 bankers (and many examiners) have participated in Jack's live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor, he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.


Credit Information

2022: What You Need to Know About Escrows has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for Live attendance only. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.