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?

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.