We discussed account collateral in a previous thread - https://www.bankersonline.com/forum/ubbt...ans#Post2172295 - and, I agree with the issues raised therein. However, if a Bank chose to do such a thing on a TRID loan, where would it be disclosed on the LE/CD? It would seem to need to be disclosed because it is a part of the transaction, as far as if there was no TRID loan here, then no deposit would be necessary.

Treat it similar to funds deposited for repairs? As noted in this thread - https://www.bankersonline.com/forum/ubbthreads.php/topics/2028427/Escrow_Holdbacks_(work_escrows