Rule worksheet · Free download
Escrow Cushion Lower-Limit Review Sheet
Check whether the mortgage documents or applicable law specify a cushion lower than the federal maximum before treating two months as an automatic required balance.
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Actual first-page previewEscrow Cushion Lower-Limit Review Sheet
Before you fill it out
What this resource helps you document
Check whether the mortgage documents or applicable law specify a cushion lower than the federal maximum before treating two months as an automatic required balance.
01Federal maximum cross-check
02Loan-document language
03Other applicable limit
04Statement cushion used
05Question to resolve
Federal baseline to check
Use the form with the rule, not instead of the rule.
These templates organize facts and records. They do not create a borrower right that the underlying regulation, loan terms, investor rules, or state law does not provide.
- Regulation X generally caps the cushion at one-sixth of estimated annual escrow disbursements.
- If the mortgage documents provide a lower cushion limit, that lower contractual limit applies; applicable federal or state law can also impose a lower amount.
- A servicer may choose a lower cushion or no cushion even when the maximum would be permitted.
Use this resource carefully
- Quote or attach the exact mortgage-document clause that sets a lower reserve; do not rely on a remembered closing conversation.
- Compare the selected cushion with the projected annual disbursement total and trial balance, not with the loan principal balance.
- If state law is believed to set a lower cap, verify the current state rule from an authoritative source before asserting a servicing error.
12 CFR § 1024.17(c)CFPB Regulation X § 1024.17(c) — Escrow calculations and cushionOpen primary source ↗12 CFR § 1024.17(c)(8)CFPB Regulation X § 1024.17(c)(8) — Mortgage documents and lower escrow limitsOpen primary source ↗CFPB consumer guidanceHow to dispute an error or request mortgage informationOpen CFPB guidance ↗