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OCC ·

OCC codifies escrow-account authority for real-estate lending

Banks may set real-estate escrow terms under OCC’s codified authority

Financial Services
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OCC issued a final rule codifying the authority of national banks and federal savings associations to establish and maintain real-estate lending escrow accounts, effective June 18, 2026.
Why it matters
The rule codifies banks’ authority to manage escrow-account terms for real-estate lending. Legal, compliance and lending-operations teams must align escrow policies with OCC’s codified framework covering account terms, interest, fees and escrow-fund administration.
Implications
  • — National bank real-estate lending teams must apply OCC’s codified escrow-account authority when establishing or maintaining escrow accounts from June 18, 2026.
  • — Federal savings association lending-operations teams must align escrow-account terms, fee practices and fund-administration procedures with the final rule.
  • — Bank legal and compliance teams must update real-estate escrow policies and internal references before the final rule takes effect.
Who is affected
  • — National bank real-estate lending teams
  • — Federal savings association lending-operations teams
  • — Bank legal and compliance teams responsible for escrow-account policies
What to watch
  • — Bulletin publication date: May 15, 2026
  • — Effective date: June 18, 2026
  • — Docket ID: OCC-2025-0736
  • — 12 CFR Parts 34 and 160
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