Internal Control Questionnaires and Verification Procedures

Servicing — Escrow Account Administration

1. Are procedures in place that ensure that the amount of escrow funds collected from each homeowner does not exceed the limit established by 12 U.S.C. 2609 (RESPA)?

2. Is every escrow account analyzed annually and an annual recap of escrow account activity sent to each consumer?

3. If an escrow account overage or shortage is found, is the homeowner notified in writing of the method that will be used to adjust the account?

4. Are controls in place that prevent the bank from using homeowners’ escrow account balances to meet other obligations?

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