Escrow Account Fraud?

Every year, I have this same complaint about Citimortgage, and every year I get no results.

My escrow statement in plain English reads ($figures have been changed to protect the innocent):
Projected low-point: $1020
Required low-point (cushion): $1000

Note that since 1976, the RESPA statute has allowed lenders to maintain a cushion equal to one-sixth of the total amount of items paid out of the account, or approximately two months of escrow payments. If state law or mortgage documents allow for a lesser amount, the lesser amount prevails.

The "Required low-point (cushion)" as Citi calls it, is actually the maximum cushion allowed by law. In other words, the federal government has told banks, "You can overestimate escrow expenditures by 16.7%. If your estimate is off by more than that, you're no longer a bad estimator, you're stealing from your customers." RESPA has drawn a line in the sand, and Citi is crossing it.

By stating that the projected low point is above the legal maximum by $20, isn't Citi openly claiming that they're going to break the law? Of course, they'll make it all better in January by graciously sending me a $20 check. Most people will get this money and think that Citi is being sooo nice. In reality, they're ripping off their customers and breaking the law with bad accounting practices.

Can anyone tell me what the best course of action is against Citi? It sure as hell isn't complaining to Citi because that gets nowhere!