Business customer requests escrow on their SBA loan... has anyone ever dealt w/ this before?

I've looked up the SBA requirements and they're pretty sticky.

Bank can only collect up to 105% of the total of the Hazard Pol/Prop Taxes.

The account that the funds are held in must be FDIC insured and collect interest to which must be paid back to the customer no less than annually.

IF customer pays off loan, funds must be reimbused no later than 15 business days.... and so on.

My thing is, we won't be able to collect a 2 month cushion so the customer will constantly be short at the end of the year.

Has anyone ever dealt w/ this before? Do you have any advice? Could you help?