Not IOLTA accounts. We have a State Charter. The question was in regards to HPML and the requirement of escrow accounts for a minimum of 365 days. Our concern was that although there was not a Federal requirement WA State may require interest to be paid on escrow balances if the lender required the borrower to set-up escrow for taxes and insurance. After further research and contact with WA DFI, WA State does not require lenders to pay interest on escrow accounts.