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Can we allow customers to open their escrow accounts at other banks? – IBA Compliance Connection

Can we allow customers to open their escrow accounts at other banks?

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While the Mortgage Escrow Account Act does require that an account pledged in lieu of an escrow account must be “with the mortgage lender,” there is no similar requirement that applies to ordinary escrow accounts. 765 ILCS 910/6. If your loan documents allow escrow accounts to be maintained at outside banks, and if you follow all state and federal requirements, we are not aware of any law that would prevent such an arrangement.