If you establish an escrow you have to follow the rules found in 1024.17. You have to perform the initial analysis and provide it within 45 days from the establishment of the escrow account.
Remember the analysis year is the 12 month period ending from the date the first escrow payment is due.
Ask your CLO and LO how they intend to fund the required initial deposit established from the initial analysis.
The opinions expressed are mine and they are not to be taken as legal advice.