Foreclosure Defense Servicer Errors

Your Escrow Payment Doubled Overnight? Challenge the Analysis

Servicers frequently miscalculate escrow accounts—projecting inflated taxes, padding insurance estimates, or building excess "cushions." When your payment suddenly spikes, you have the right to demand a corrected analysis.

12 CFR 1024.17
RESPA Escrow Rules
2-Month
Maximum Cushion
30 Days
Response Required
Annual
Statement Required

How Escrow Accounts Work

Your monthly mortgage payment typically includes principal, interest, AND escrow. The escrow portion covers property taxes and homeowner's insurance. Your servicer collects these funds monthly, holds them, and pays your taxes and insurance when due.

Under 12 CFR 1024.17, servicers must perform an annual escrow analysis and can only maintain a "cushion" of up to 2 months' worth of escrow payments.

Common Escrow Errors

Inflated Tax Projections

Using wrong tax parcel, projecting increases that didn't happen, or doubling payments

Insurance Padding

Projecting premium increases far beyond actual policy cost or using force-placed rates

Excess Cushion

Holding more than 2 months' cushion—the maximum allowed under RESPA

Shortage Spread

Demanding immediate lump-sum shortage payment instead of 12-month spread

Reading Your Escrow Statement

Your annual escrow analysis statement must show:

  1. Projected disbursements - What they expect to pay for taxes and insurance
  2. Current balance - How much is in your escrow account now
  3. Target balance - Minimum they must maintain (with cushion)
  4. Shortage/surplus - Difference between current and target
  5. New monthly payment - Your adjusted payment going forward

Verify the Tax Amount

The #1 escrow error is wrong property tax projections. Look up your actual tax bill on your county assessor's website and compare it to what the servicer is projecting. They often use the wrong parcel or inflate expected increases.

Your Rights Under RESPA

The Real Estate Settlement Procedures Act gives you important escrow protections:

Cushion Limit

Servicers can only hold a cushion equal to 2 months of escrow payments (1/6 of annual disbursements). Anything more violates RESPA.

Shortage Options

If your escrow account has a shortage, you have options:

Surplus Refund

If your escrow has a surplus over $50, the servicer must refund it within 30 days. Smaller surpluses can be credited to future payments.

California Add-On

California CC § 2954 also regulates escrow impound accounts, limiting amounts servicers can collect and requiring proper accounting.

Sample Escrow Dispute Letter

[Your Name] [Your Address] [City, State ZIP] [Date] Via Certified Mail, Return Receipt Requested [Servicer Name] [Servicer Address] [City, State ZIP] Re: Notice of Error - Escrow Account Analysis Loan Number: [LOAN NUMBER] Property: [PROPERTY ADDRESS] Dear Sir or Madam: This is a Notice of Error under 12 CFR 1024.35 regarding errors in my escrow account analysis dated [DATE OF STATEMENT]. IDENTIFIED ERRORS: 1. INCORRECT TAX PROJECTION Your analysis projects annual property taxes of [$X,XXX]. However, my actual tax bill from [COUNTY] County for [TAX YEAR] is [$X,XXX]. This is an overstatement of [$XXX]. [Attach copy of actual tax bill] 2. EXCESS CUSHION Your analysis maintains a cushion of [$X,XXX], which exceeds the 2-month maximum permitted under 12 CFR 1024.17(c)(1)(i). Based on projected disbursements of [$X,XXX]/year, the maximum cushion should be [$XXX] (1/6 of annual disbursements). 3. [INSURANCE OVERSTATEMENT / OTHER ERROR] [Describe additional error] REQUESTED CORRECTIONS: 1. Recalculate escrow analysis using actual tax amounts 2. Reduce cushion to RESPA-compliant level 3. Refund any surplus exceeding $50 within 30 days 4. Issue corrected escrow analysis statement 5. Adjust my monthly payment to reflect accurate projections Under 12 CFR 1024.35, you must acknowledge this notice within 5 business days and complete your investigation within 30 business days. I am also requesting my complete escrow account history under 12 CFR 1024.36. Sincerely, [Your Signature] [Your Printed Name] Enclosures: - Copy of actual property tax bill - Copy of homeowner's insurance declaration page

FAQ

It depends on why. Legitimate reasons for large increases include:

  • Property tax reassessment (common after purchase or remodel)
  • Insurance premium increase (especially in fire/flood zones)
  • Previous escrow shortage being corrected

Illegitimate reasons to challenge:

  • Wrong tax amount or parcel number
  • Force-placed insurance when you have coverage
  • Cushion exceeding 2-month limit
  • Not being offered 12-month shortage spread

Possibly, but it depends on your loan terms and LTV:

  • Many loans require escrow until you reach 80% LTV
  • Some loan types (FHA, VA) always require escrow
  • Your lender may charge a fee to cancel escrow

To cancel, submit a written request. If denied, ask for the specific reason and cite the governing regulation.

Under RESPA, servicers must:

  • Acknowledge your notice within 5 business days
  • Respond substantively within 30 business days (can extend to 45)

If they miss these deadlines, they've violated RESPA. You can file a complaint with the CFPB and potentially recover statutory damages ($2,000 for pattern/practice violations) plus actual damages and attorney fees.

You have options:

  • Pay in full - Eliminates monthly shortage addition
  • 12-month spread - Federal law requires this option. Shortage is divided by 12 and added to monthly payment
  • Dispute the amount - If the shortage is based on wrong projections, dispute it first

Never ignore an escrow shortage notice. If you disagree, dispute it in writing while also making your current payment to avoid default.

$240/hour

Escrow Analysis Doesn't Add Up?

I help California homeowners challenge inflated escrow calculations and demand RESPA-compliant accounting. If your payment spiked due to servicer error, I can help you fight back.

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