We are planning to roll out some new construction products for 1-4 family residential homes and have a question regarding contingency reserves that we will hold. For example, we will require the borrower to place say 5% of the loan amount into a contingency account that we can use if there are added expenses with the construction. If everything goes well and this money isn't needed we will refund this to the borrower upon conversion to permanent financing. My question is are we required to pay interest on this money?