Well, allowing a customer to establish an escrow account in conjunction with a HELOC is highly unusual. But if you allow setting up escrow accounts in conjunction with HELOCs, then it would have to be a voluntary action by the applicants as there are no State or Federal laws or other required escrow account provisions tripped that would require it. In that case, you would need an acknowledgement that it was voluntarily established by the applicant. If you do not offer escrows with HELOCs, then the document becomes a moot point.
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