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We do not require our mortgage customers to establish escrow accounts. Are we still required to comply with the notice provisions in the Illinois Mortgage Escrow Account Act? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We do not require our mortgage customers to establish escrow accounts. Are we still required to comply with the notice provisions in the Illinois Mortgage Escrow Account Act?

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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.