I vote no:
12 CFR § 34.4 Applicability of state law.
(a) A national bank may make real estate loans under 12 U.S.C. 371 and § 34.3, without regard to state law limitations concerning:
(6) Escrow accounts, impound accounts, and similar accounts;
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com