Can we require a borrower to maintain an account with us with a certain amount of reserves, to be held for a certain amount of time, as a closing requirement?

Basically it's assurance that we will receive payments.

Yes. Be mindful of Reg Z if this is a consumer loan.

Be mindful of Reg Z in what aspect?

Are you referring to 226.18 (r)" If a consumer must maintain a << deposit>> account to get a loan, you must include a statement in your disclosure that the APR does not reflect the effect of the << required deposit>> ."?

Yes.

OK will do. Thanks again for your help.

Thank goodness for Bankers' Threads.