IBA Compliance Connection

Your go to source for compliance!

We have been providing a copy of the Mortgage Escrow Account Act and the Mortgage Tax Escrow Act at the time of loan application. Can we instead provide the notice at the loan closing?

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The Mortgage Escrow Account Act requires you to provide notice of the Act’s requirements “at the date of closing,” not at the time of the loan application. 765 ILCS 910/11. We do not believe any notice is required under the Mortgage Tax Escrow Act. See 765 ILCS 915/0.01 et seq.