We are considering requiring an escrow account on CRE loans for the payment of property taxes. This would be for those borrowers who in the past have not demonstrated their ability or choice to keep property taxes current?
Since these are not subject to Reg. Z or RESPA my thought is that we can do it without any of the hassles/calculations/maximums etc. associated with a consumer transaction. Is there something I am not considering?

Appreciate your comments.

It just becomes a contractual issue at that point, since it's not subject to any regulatory issues.