We recommend complying with the Mortgage Escrow Account Act’s notice provisions for all purchase money mortgages secured by single-family, owner-occupied residential properties, even though escrow accounts are not mandatory at your institution. The Act does not distinguish between mandatory or voluntary escrow accounts, and further, it does not distinguish between loans that have escrow accounts and those that do not. See 765 ILCS 910/5765 ILCS 910/11.