Real Estate Lending Escrow Accounts (OCC)

Current understanding

To be populated as evidence accumulates.

Evidence log

• 2026-05-19 — Real Estate Lending Escrow Accounts: OCC finalizing rule to codify national banks’ and federal savings associations’ existing authority to establish and manage real estate lending escrow accounts, including discretion over fees and compensation terms. (novelty: 2) (novelty: 2)
• 2026-05-19 — Preemption Determination: State Interest-on-Escrow Laws: OCC issued a final preemption determination concluding that federal law preempts state laws restricting national banks’ discretion to pay interest or charge fees on real estate escrow accounts. (novelty: 3)

Open questions

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