We're thinking of eliminating offering escrow accounts on our loans. We do not offer loans that would "require" excrow and we do not require escrow with any of our loan products. This was something that we offered in the event the borrower requested it.

Would we be required to continue offering the excrow accounts for those which are established on existing loans? If so where do I find this requirement. Of course if we discontinue the service we would payout the entire funds in the account to the borrower and provide them with notice.