Charging or receiving a fee for force placing insurance is going to be a State law issue as you indicated. In many States unless you are licensed to sell insurance, receiving monetary gain due to the issuance of a policy would be prohibited.
As far as assessing an annual fee for maintaining escrow accounts, just realize that any such fee would be a finance charge and would have to be factored into the APR.
Also, suggest your management read the war path message from the CFPB below concerning "junk fees". Excuse my French, but this is the type of [censored] that gives the industry a bad name. Price your loans accordingly and quit the nickel and dime stuff.https://www.consumerfinance.gov/abo...to-save-americans-billions-in-junk-fees/