I'd say yes. Here's the definition of 'escrow account' from Reg. X (3500.17(b)):
Quote:
Escrow account means any account that a servicer establishes or controls on behalf of a borrower to pay taxes, insurance premiums (including flood insurance), or other charges with respect to a federally related mortgage loan, including charges that the borrower and servicer have voluntarily agreed that the servicer should collect and pay. The definition encompasses any account established for this purpose, including a ``trust account'', ``reserve account'', ``impound account'', or other term in different localities. An ``escrow account'' includes any arrangement where the servicer adds a portion of the borrower's payments to principal and subsequently deducts from principal the disbursements for escrow account items. For purposes of this section, the term ``escrow account'' excludes any account that is under the borrower's total control.
_________________________
Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."
Previous Thread
Index