- Business Rules
If our customer does not escrow do we still need to disclose HOA fees over the first year?What will be required is a statement that the consumer will not have an escrow account, the reason why an escrow account will not be established, a statement that the consumer must pay all property costs, such as taxes and homeowner’s insurance, directly, a statement that the consumer may contact the creditor to inquire about the availability of an escrow account, and a table, titled "No Escrow," that contains, if an escrow account will not be established, an itemization of the following:
The estimated total amount the consumer will pay directly for charges described in §1026.37(c)(4)(ii) during the first year after consummation that are known to the creditor and a statement that, without an escrow account, the consumer must pay the identified costs, possibly in one or two large payments, labeled "Property Costs over Year 1."
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here