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During a disclosure desk review, the branch manager encounters an RESPA Escrow Requirements issue. Which response should resolve the issue before the file moves forward?

Correct Answer

B) Apply RESPA escrow-account rules to the account

Why this is correct: RESPA regulates escrow accounts for certain mortgage loans. Its rules cover how much can be collected (limiting the cushion), require initial and annual statements, and mandate escrow accounts for High-Priced Mortgage Loans (HPMLs). Applying these specific RESPA rules to the escrow account is the correct way to resolve the issue. Why the other choices are wrong: "Change the payment without reviewing escrow-account figures." is wrong because it would lead to an arbitrary, likely incorrect adjustment instead of a calculation based on RESPA rules. "Apply the credit underwriting timing rule even though the file is testing RESPA Escrow Requirements." is wrong because it applies a rule from a different regulatory area (underwriting) to an escrow issue. "Wait for a regulator request before correcting the escrow treatment." is wrong because proactive compliance is required; waiting for a regulator to find the error is not defensible. Exam tip: RESPA escrow rules limit the cushion to 1/6 of the annual disbursements. Remember this for cushion calculation questions.

Answer Options
A
Change the payment without reviewing escrow-account figures.
B
Apply RESPA escrow-account rules to the account
C
Apply the credit underwriting timing rule even though the file is testing RESPA Escrow Requirements.
D
Wait for a regulator request before correcting the escrow treatment.

Why This Is the Correct Answer

The correct response is "Apply RESPA escrow-account rules to the account" because Escrow rules address taxes, insurance, cushion limits, statements, and HPML escrow duties.

Why the Other Options Are Wrong

Option A: Change the payment without reviewing escrow-account figures.

Change the payment without reviewing escrow-account figures. is not correct because it does not apply the rule tested by this file scenario.

Option C: Apply the credit underwriting timing rule even though the file is testing RESPA Escrow Requirements.

This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.

Option D: Wait for a regulator request before correcting the escrow treatment.

Wait for a regulator request before correcting the escrow treatment. is not correct because it does not apply the rule tested by this file scenario.

Memory Technique

escrow-account analysis and shortage treatment: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.

Exam Tip

Match the file facts to escrow-account analysis and shortage treatment; do not choose an exception or shortcut that skips the required rule.

Common Mistakes to Avoid

  • -Choosing an internal exception instead of the governing rule
  • -Treating preliminary or informal facts as a substitute for required documentation
  • -Answering from a familiar but unrelated mortgage topic
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