Can an escrow account be set up in conjunction with the origination of a dwelling secured loan (no land) and no initial escrow deposit be collected? Instead, it seems like the initial escrow deposit amount is divided over 12 months and added to monthly escrow payment that was calculated using the aggregate analysis. Is that ok?

If there is no land involved, then RESPA does not apply, and you can do whatever you and the borrower agree to.

Thanks!