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Repair Windows errors before they cause bigger problemsFix Now →Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →To check whether a new mortgage payment is correct, reconcile your escrow statement in four parts: last year’s deposits and payouts, next year’s tax and insurance estimates, any shortage repayment, and the account cushion. A higher payment may reflect higher projected bills, repayment of a shortage, or both. Find the specific amount, date, or projection that does not match your records before contacting your servicer.
This guide covers general U.S. rules for federally related mortgage loans with escrow accounts. Coverage, exceptions, loan terms, and state law can affect how the rules apply to an individual loan.
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What an annual escrow analysis should show
Regulation X describes escrow account analysis as a trial running balance used to set target balances, calculate payments for the next computation year, and identify shortages, surpluses, or deficiencies. The servicer generally must send an annual statement within 30 calendar days after the escrow computation year ends. See the CFPB’s Regulation X, 12 CFR § 1024.17.
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1Clear out junk files and repair common Windows errors2Scan for outdated or missing drivers - takes under a minute3Repair Windows errors before they cause bigger problemsCheck that the statement lets you trace both what happened during the past year and what the servicer expects for the next one. It should include the current and prior monthly payment and escrow portion, past-year deposits, itemized payments for taxes, insurance, and other charges, the ending balance, and the treatment of any surplus, shortage, or deficiency. Where relevant, it should compare projected and actual low balances.
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Reconcile the statement against your records
- Check deposits. Compare each escrow deposit in the account history with the escrow portion of your mortgage payments and your payment records. Flag a payment or credit that is missing or posted for the wrong amount or date.
- Check disbursements. Match each tax, insurance, or other payout to the bill or invoice. Verify the amount, payee, and payment date; check whether the tax or insurance bill was paid by its deadline to avoid a penalty.
- Compare last year’s estimates with actual bills. Look at what the prior analysis projected, then compare it with the amounts actually charged. For the coming computation year, a servicer must use a charge amount it knows; if the amount is not known, it may generally use the previous year’s charge or adjust it by no more than the most recent annual change in the all-items Consumer Price Index. The applicable calculation is set out in Regulation X, 12 CFR § 1024.17.
- Rebuild the projected balance. Follow the statement’s running balance through the next year. Check the monthly escrow contribution, any separate shortage collection, projected low balance, and cushion. A spreadsheet or paper worksheet can help you check the arithmetic, but it cannot establish whether an underlying bill or legal assumption is correct.
Separate the reasons your payment changed
Do not treat the new monthly payment as one unexplained “escrow increase.” Compare these components separately:
- Next-year tax and insurance estimates: Higher expected bills can increase the monthly escrow contribution even when last year’s deposits and payouts were correct.
- Shortage repayment: If the account fell below its target balance, the servicer may collect the shortage in addition to the contribution for next year’s bills.
- Cushion and projected low balance: Check the target balance the analysis uses and how it affects the monthly amount.
Regulation X distinguishes a shortage, measured against the target balance at analysis, from a deficiency, which is a negative account balance. They are not interchangeable. Use the statement’s account history and projected running balance to identify which one it reports.
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For covered escrow accounts, the cushion is generally limited to one-sixth of estimated annual disbursements—two months of those estimated disbursements. Loan documents or applicable law may impose a lower limit. Compare the cushion with the figures in the analysis rather than assuming that any stated target is automatically permitted. See Regulation X, 12 CFR § 1024.17.
Check how a surplus or shortage is handled
Use the reported balance and the account’s projected low point to understand the adjustment. For a current borrower, a surplus of at least $50 generally must be refunded within 30 days of the analysis. For a smaller surplus, the servicer may refund it or credit it against future escrow payments.
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Shortage repayment options depend on its size. A shortage below one monthly escrow payment may be left in the account, collected within 30 days, or spread over at least 12 months. A larger shortage may be left in the account or spread over at least 12 months. Compare the amount and schedule shown on your statement with its running-balance figures. These rules and exceptions are in Regulation X, 12 CFR § 1024.17.
Look for specific mismatches
A discrepancy is easier to investigate when you can identify the exact line and period that do not agree. Check for:
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- A mortgage payment, escrow deposit, or credit missing from the account history.
- A tax or insurance payout whose amount, payee, or date differs from the bill or invoice.
- A tax bill marked unpaid even though the escrow history shows a payment, or a payment made late despite sufficient escrow funds.
- A next-year estimate that does not use a charge amount the servicer already knew.
- A cushion that appears to exceed the applicable limit, without accounting for a lower cap in your loan documents or state law.
- A shortage amount or repayment schedule that does not follow the statement’s own projected balance.
If property taxes were not paid from escrow, the CFPB advises borrowers to send a copy of the tax bill with a notice of error. Its consumer guidance on escrow and mortgage disputes is available at What should I do if I’m having problems with my escrow or impound account?.
Send a written notice of error
If you find a suspected servicing error, write to the servicer at its designated address for notices of error. Do not assume the address for regular payments or general customer service is the correct one. Include your name and loan identifier, and make the concern specific enough for the servicer to investigate.
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- Identify the statement line, amount, and date or period in question.
- Explain what you believe is wrong and what record supports your position—for example, a payment confirmation, property-tax bill, or insurance invoice.
- Attach copies of relevant records, including a tax bill if the issue is an unpaid property-tax bill. Keep the originals.
- Keep a copy of the letter and attachments, along with proof of delivery.
The CFPB explains how to dispute a mortgage servicing error in How do I dispute an error or request information about my mortgage?. For covered notices, the servicer generally must acknowledge receipt within five business days and correct the error or investigate and respond within 30 business days. For many errors, it may extend the response period by 15 business days if it gives written notice of the extension and its reasons before the original deadline. Exceptions and different deadlines apply to specified error types; see Regulation X, 12 CFR § 1024.35.
Keep making scheduled mortgage payments while the servicer investigates. Sending a notice does not change your payment obligations. If the servicer does not respond, CFPB guidance describes submitting a complaint or contacting a HUD-approved housing counselor. If foreclosure is imminent or you have been served legal papers, seek prompt legal help.
Payment timing and escrow after payoff
For covered escrow accounts, the servicer generally must pay escrowed items by the deadline to avoid a penalty if your mortgage payment is no more than 30 days overdue. When the mortgage is paid in full, the servicer generally must return remaining escrow funds within its control within 20 business days, subject to regulatory exceptions. See Regulation X, 12 CFR § 1024.17 and Regulation X, 12 CFR § 1024.34.
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