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If a customer chooses to open an “interest bearing time deposit” account in lieu of an escrow account, does that have to be a certificate of deposit or could it be a regular savings account (without any premature withdrawal penalties)? – IBA Compliance Connection

IBA Compliance Connection

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If a customer chooses to open an “interest bearing time deposit” account in lieu of an escrow account, does that have to be a certificate of deposit or could it be a regular savings account (without any premature withdrawal penalties)?

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The Act does not define the term “interest bearing time deposit.” Therefore, we must interpret the term by its plain language, keeping in mind that the purpose of that section is to allow borrowers to benefit from the interest earned on the money held for payment of taxes. Stern v. Norwest Mortgage, Inc., 179 Ill.2d 160, 165 (1997). If you offer an account that does not impose a withdrawal penalty, such a consumer-friendly feature would not likely violate Section 6 of the Act. 765 ILCS 910/6. Be careful. You could probably stretch the phrase to cover a deposit account that is not a certificate of deposit account.