We recommend contacting the insurance company to inquire about the status of the check and to determine what amount of the check is refundable to your former borrower’s estate. In any event, if the loan has remained current and there is a surplus of over $50 in the mortgage loan escrow account, that surplus should be refunded within 30 days of the escrow analysis date to the borrower’s estate or a representative of the borrower’s estate (not to the borrower’s son and daughter as individuals).

For resources related to our guidance, please see:

• Regulation X, 12 CFR 1024.17(f)(2) (“If an escrow account analysis discloses a surplus, the servicer shall, within 30 days from the date of the analysis, refund the surplus to the borrower if the surplus is greater than or equal to 50 dollars ($50). If the surplus is less than 50 dollars ($50), the servicer may refund such amount to the borrower, or credit such amount against the next year’s escrow payments.”)