We are getting tons of borrowers requesting to either close their escrow accounts to pre-pay their 2018 taxes in 2017 as a result of the new federal tax bill and Cuomo's Executive Order allowing pre-payment of 2018 tax bills.

Have any of you in NY heard about this Executive Order and have your banks decided how you're going to handle things operationally? What are you doing for those who have more than 80% LTV? Are you going to allow your borrowers to withdraw from their escrow account? Can they even do that?

https://www.governor.ny.gov/news/governo...ity-new-yorkers

Not in NY, nor do we offer escrows, but it seems like it will be a headache to manage if you allow borrowers to cancel their escrow early.

Regulation Z currently requires creditors to establish escrow accounts for higher-priced mortgage loans secured by a first lien on a principal dwelling. not sure how a governor could override reg. z

But he didn't he is just allowing people to prepay their 2018 taxes in 2017.this will not roll in additional years. And yes it is going to be a nightmare to ensure that all is paid appropriately by the banks and not double paid.