Topic: Real Estate Settlement Procedures Act (RESPA)
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Is a single-item analysis required for each escrow account item before the aggregate analysis is completed? We are not sure, because RESPA requires aggregate analysis but includes a definition for “single-item analysis,” and HUD’s guidance states that single-item analysis is required.
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We believe that the single-item analysis calculation method has been phased out. In its place, the RESPA rules require you to use the aggregate accounting method when conducting any escrow account analysis, whether the initial analysis or an annual analysis. 12 CFR 1024.17(c)(4). Of course, you should separately itemize the taxes, insurance premiums and other…