Answer:
Answer by Randy Carey: A lender would be allowed to modify the escrow agreement under these circumstances through a written modification.
Answer:
Answer by Dan Persfull: You can discontinue a non-HPML escrow account any time both parties agree to terminate the account.
You need to review 3500.17 thoroughly for the definition of a "voluntary escrow". To be a true voluntary escrow the consumer must have full and complete control over the account. In other words they can make a deposit, withdrawal, close the account, etc at any time they wish without the consent of the bank.
First published on BankersOnline.com 3/7/11
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