when is an escrow account required
3 After the first year, a borrower can ask the lender to opt out of the escrow account, but the lender has the right to reject the request. The effective date for the HOEPA escrow requirements is April 1, 2010, with an extension to October 1, 2010 for manufactured homes. Financial institutions offering loans qualifying as higher-priced mortgage loans will be required to provide escrow accounts for those loans.