Answer:
Yes, a HELOC loan can have an escrow account. You are allowed to have/require an escrow account on any loan type (e.g., commercial, residential, HELOC), subject to any state law restrictions. If you are requiring it, as opposed to offering it in response to the customer's request, be sure to consider the fair lending implications. It's important to ensure you are not requiring the escrow on a prohibited basis, and to have set escrow requirements for all borrowers to follow.
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