It depends. The annual escrow account statement required by RESPA by itself will not satisfy the Illinois Mortgage Escrow Account Act’s notice requirements, but it can if you add language to the notice stating that the bank’s contact information in the notice provides a means for accessing the dates and amounts of the borrower’s property tax payments.

The Illinois Mortgage Escrow Account Act requires lenders to notify borrowers when making property tax payments and permits this notice to be combined with other notices, such as the RESPA annual escrow account statement. However, the notice must provide “a means of communication for the borrower to access” the date and amount of tax payments and an identification of the property “by telephone, facsimile, e-mail, Internet access, or other means of communication . . . .” If your RESPA annual escrow account statements include contact information (such as your bank’s phone number, email address, or internet website) and indicate that the contact information provides a means of accessing the required information about property tax payments, this would satisfy the Illinois law’s requirements.

For resources related to our guidance, please see:

• Mortgage Escrow Account Act, 765 ILCS 910/15(c) (“[A] mortgage lender that provides notice at least annually to a borrower in the manner provided in subsection (b) of a means of communication for the borrower to access the information set forth in subsection (a) [notice of tax payments] by telephone, facsimile, e-mail, Internet access, or other means of communication, is deemed to be in compliance with subsection (a).”)