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Are there any compliance issues with starting an escrow account on a consumer loan after the loan has closed? I was thinking there would be because all the early disclosures mention, “does this loan have an escrow account?” If we said no then and now add one, I feel like that would be out of compliance….
Your bank may implement escrow for an existing loan by having the borrower(s) sign an escrow agreement (the borrower would have to agree to it) and sending them the initial escrow statement within 45 days of establishing the escrow account. With that said, it shouldn’t be a standard practice to wait until after closing to establish escrow accounts.
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