CFPB issues FAQs on escrow accounts, Regulation E

June 8, 2021

The Consumer Financial Protection Bureau (CFPB) recently issued sets of frequently asked questions on Electronic Fund Transfer Act and Regulation E requirements, as well as servicing escrow accounts under Regulation X.

The Regulation E FAQs address situations in which a consumer is fraudulently induced by a third party to provide their account information or private network rules conflict with the regulation, among others. 

The Regulation X FAQs are broken down into four categories:

  • General;
  • Escrow account analysis;
  • Deficiencies, shortages, and surpluses; and
  • Public guidance documents.

In addition to restating the regulation, the questions describe the CFPB's approach to the public guidance documents and their relationship to the Department of Housing and Urban Development's prior guidance.