Based on my understanding of the regulation I don’t believe that a bank is required to notify a borrower that they can cancel their escrow after five (5) years.
The regulation states that the bank may cancel an escrow if at the earlier of either:
(A)Termination of the underlying debt obligation; or
(B)Receipt no earlier than five years after consummation of a consumer’s request to cancel the escrow account.
If the bank receives a consumers request then:
The borrower must request the cancellation of the escrow account only aand they satisfy the follwoing conditions: (A)The unpaid principal balance is less than 80 percent of the original value of the property securing the underlying debt obligation; and
(B)The consumer currently is not delinquent or in default on the underlying debt obligation.
Reference : § 1026.35(b)(3)(ii)