Do we have to disclose to/notify customers if we change the date in which we pay interest on escrow? Thanks.

That may be better asked in your state forum since only some states require this.

Oh, thanks Andy, didn't know.

In Texas we don't have to pay interest on escrows. So change dates are foreign to me. I'd guess that either state laws or your existing contract covers this. But your state forum may discuss what is required and what is a best practice.

Yes Andy, remember, I'm from Mass, clearly the most consumer friendly state in the nation! We have laws (compliance ones anyway) that would make you fall down laughing. Whatever benefits the customer the most, we must do. As a customer, it's great living in the state, as a banker, it's extremely frusturating! John B will agree with me I think (from his former life anyway). Often times, duplicating federal law or contradicting it. Fun times I tell ya, not! So, yes, we must pay interest on real estate tax escrows.

After I started hearing some of John's "war stories" I put Mass right up there with CA when it comes to consumer protections.

We in Texas only started home equity loans a few years ago. They weren't allowed until then. Sort of a simplistic way of doing things. Compliance was easy, "you just can't do that."