📋 What is an Escrow Dispute?

An escrow is a neutral third-party arrangement where funds, documents, or property are held pending the fulfillment of contractual conditions. In California, escrow companies are licensed and regulated by the Department of Financial Protection and Innovation (DFPI). Escrow disputes arise when there are disagreements about fees charged, how funds should be disbursed, delays in releasing funds, or when escrow holders fail to follow proper instructions.

When to Use This Guide

Use this guide if you have a dispute with an escrow company or escrow holder involving:

💰 Unauthorized Fees

Escrow charged fees not disclosed or agreed upon in the escrow instructions

🚫 Disbursement Errors

Funds were released to the wrong party or in incorrect amounts

⏲ Delayed Fund Release

Escrow is unreasonably holding funds after closing conditions are met

📄 Instruction Violations

Escrow failed to follow the written escrow instructions

👍 What You Can Recover

  • Refund of unauthorized fees - Any fees charged without proper disclosure or authorization
  • Wrongfully withheld funds - The full amount that should have been disbursed to you
  • Interest on delayed funds - Interest for the period funds were improperly held
  • Consequential damages - Losses caused by escrow errors (failed transactions, penalties, etc.)
  • Attorney fees - If your escrow instructions contain a fee provision

Common Escrow Dispute Scenarios

💰 Unauthorized or Excessive Fee Charges

Escrow companies must disclose all fees before you sign escrow instructions. If fees appear on your settlement statement that were not disclosed, or if fees exceed the quoted amounts without explanation, you may be entitled to a refund. California Financial Code requires escrow companies to provide clear fee disclosures and prohibits deceptive practices.

🚫 Improper Fund Disbursement

Escrow holders have a strict duty to follow written escrow instructions. If funds were released to the wrong party, released before conditions were satisfied, or released in incorrect amounts, the escrow company may be liable for the error. This is a breach of their fiduciary duty as a neutral stakeholder.

Unreasonable Delays in Releasing Funds

Once all escrow conditions are satisfied, the escrow holder must promptly disburse funds according to the instructions. Unreasonable delays - especially when holding funds while disputes are manufactured or while seeking additional documentation already provided - can entitle you to interest and damages.

🔒 Refusal to Release After Cancellation

When a transaction is cancelled and there is a dispute over who is entitled to the funds, escrow companies often require mutual release instructions. California Civil Code 1057.3 provides a specific procedure for demanding release of disputed funds. If escrow is improperly refusing to release funds that clearly belong to you, you have legal remedies.

📄 Failure to Follow Instructions

Escrow holders are agents bound by written instructions. They cannot deviate from those instructions without written consent from all parties. Common violations include closing before all conditions are met, failing to obtain required documents, or acting on oral instructions that contradict written ones.

⚠ Time is Critical

California has a 4-year statute of limitations for written contract claims and a 2-year limit for negligence claims. Additionally, DFPI complaints should be filed promptly while evidence is fresh. For escrow matters involving real estate transactions, evidence can become stale quickly as parties move on and records are archived.

Evidence Checklist

Gather these documents before sending your demand letter. Click to check off items as you collect them.

📄 Escrow Documents

  • Signed escrow instructions (all versions/amendments)
  • General provisions and escrow terms
  • Fee schedule or good faith estimate
  • Escrow number and escrow officer contact info

💰 Financial Records

  • Settlement statement (HUD-1 or Closing Disclosure)
  • Wire transfer confirmations or deposit receipts
  • Bank statements showing funds sent/received
  • Invoices or fee statements from escrow

📩 Communications

  • All emails with escrow officer/company
  • Written correspondence and faxes
  • Notes of phone conversations with dates/times
  • Demands already sent requesting resolution

🔍 Transaction Documents

  • Purchase agreement or underlying contract
  • Amendments to the purchase agreement
  • Cancellation or release documents
  • Evidence conditions were satisfied/unsatisfied

🔒 Preserve All Evidence

Keep originals of all documents. Request copies of the complete escrow file from the escrow company - you are entitled to your file. Screenshot emails and save all electronic communications. Document all phone calls with follow-up written confirmation. Evidence of when conditions were satisfied is crucial.

💰 Calculate Your Damages

In escrow disputes, your damages depend on the type of escrow holder misconduct. Here is what you may recover.

Category Description
Unauthorized Fees Full refund of any fees charged without proper disclosure or authorization
Wrongfully Withheld Funds The amount that should have been disbursed to you
Interest on Delayed Funds Interest at the legal rate (10% per annum) for the delay period
Consequential Damages Losses directly caused by escrow errors (failed transactions, penalties, additional costs)
Attorney Fees If escrow instructions contain attorney fee provision, or in certain statutory claims

💡 Interest Calculation

California law provides for interest at 10% per annum on money wrongfully withheld (Civil Code 3289). If your escrow company is holding $50,000 for 6 months without justification, that is $2,500 in interest alone. Calculate your interest from the date funds should have been released.

📊 Sample Damages Calculation

Example: Unauthorized Fees + Delayed Disbursement

Unauthorized "document preparation" fee $350
Undisclosed wire transfer fee $75
Funds wrongfully withheld (45 days) $25,000
Interest on delayed funds (45 days at 10%) $308
Lost opportunity cost (documented) $1,200
Attorney fees (if recoverable) $3,500
POTENTIAL TOTAL RECOVERY $30,433

💰 Consequential Damages May Be Significant

If escrow errors caused your transaction to fail, you may have substantial consequential damages: inspection costs, appraisal fees, loan application fees, moving expenses, temporary housing costs, price increases on alternative properties, and more. Document all costs caused by the escrow holder's breach.

📝 Sample Language

Copy and customize these paragraphs for your demand letter.

Opening Paragraph - Fee Dispute
I am writing to formally demand a refund of unauthorized fees charged in connection with Escrow Number [ESCROW NUMBER] for the transaction involving property at [PROPERTY ADDRESS]. As detailed below, [ESCROW COMPANY NAME] charged fees totaling $[AMOUNT] that were not disclosed in the escrow instructions, fee schedule, or good faith estimate, in violation of California Financial Code Section 17410 and the escrow company's fiduciary duties.
Opening Paragraph - Wrongful Disbursement
I am writing to formally demand payment of $[AMOUNT] from [ESCROW COMPANY NAME] for funds that were improperly disbursed in violation of the escrow instructions for Escrow Number [ESCROW NUMBER]. Despite clear written instructions requiring [SPECIFIC CONDITION OR INSTRUCTION], your company released $[AMOUNT] to [WRONG RECIPIENT] on [DATE], breaching your fiduciary duty and causing me direct financial harm.
Opening Paragraph - Delayed Fund Release
I am writing to demand the immediate release of $[AMOUNT] currently being held by [ESCROW COMPANY NAME] in Escrow Number [ESCROW NUMBER], plus interest at the legal rate for the period of wrongful withholding. All conditions for release of these funds were satisfied on [DATE CONDITIONS MET], yet as of the date of this letter - [NUMBER] days later - you continue to withhold my funds without legal justification.
Legal Basis - Fiduciary Duty Breach
As an escrow holder licensed under California Financial Code Section 17200, [ESCROW COMPANY NAME] owes fiduciary duties to all parties to the escrow, including the duty to follow written instructions, the duty of care, and the duty of disclosure. California courts have consistently held that escrow holders are liable for damages caused by breach of these duties. (See Lee v. Escrow Consultants, Inc. (1989) 210 Cal.App.3d 915.) Your conduct in [DESCRIBE BREACH] constitutes a breach of these duties, for which you are liable.
Demand - Fee Refund
I hereby demand that [ESCROW COMPANY NAME] refund the following unauthorized fees within [10/15] days of this letter: [LIST FEES AND AMOUNTS]. Total refund demanded: $[TOTAL AMOUNT]. These fees were not disclosed as required by law and were not authorized in the escrow instructions I signed. If the full refund is not received by the deadline, I will file a complaint with the California Department of Financial Protection and Innovation and pursue all available legal remedies.
Demand - Fund Release with Civil Code 1057.3
Pursuant to California Civil Code Section 1057.3, I hereby submit this written demand for release of all funds held in Escrow Number [ESCROW NUMBER] in the amount of $[AMOUNT]. Under Civil Code 1057.3, you are required to send written notice of this demand to all other parties. If no written objection is received within 30 days of your notice, you are required to release the funds to me. Failure to comply with this statutory procedure will subject [ESCROW COMPANY NAME] to liability for damages and attorney fees incurred in obtaining the release of these funds.

🚀 Next Steps

What to do after sending your demand letter.

Expected Timeline

Days 1-5

Escrow company receives and reviews your demand letter

Days 5-15

Escrow company responds or requests additional information

Days 15-30

Negotiate resolution or proceed to regulatory complaints

30+ Days

Civil Code 1057.3 objection period expires; escalate to court if needed

If They Refuse to Resolve

  1. File DFPI Complaint

    The California Department of Financial Protection and Innovation (DFPI) licenses and regulates escrow companies. File a complaint at dfpi.ca.gov. DFPI can investigate, order restitution, and impose license discipline. This is often the most effective leverage.

  2. Interpleader Action

    If there is a genuine dispute over who is entitled to escrow funds, the escrow company may file an interpleader action - depositing the funds with the court and letting the parties litigate. You can also petition the court to compel interpleader if escrow is unreasonably holding funds.

  3. Small Claims Court (Up to $12,500)

    For fee refunds or smaller damage amounts, small claims court is fast, inexpensive, and does not require an attorney. File in the county where the escrow company is located or where the transaction occurred.

  4. Superior Court Lawsuit

    For larger amounts or complex disputes, file in Superior Court. Claims may include breach of fiduciary duty, breach of contract, negligence, and violation of Financial Code. If your escrow instructions have an attorney fee clause, the prevailing party can recover fees.

  5. Mediation/Arbitration

    Some escrow instructions contain arbitration clauses. Check your escrow instructions for dispute resolution requirements before filing suit.

⚠ DRE-Licensed Escrows

If your escrow was handled by a real estate broker (not an independent escrow company), complaints go to the California Department of Real Estate (DRE), not DFPI. Similarly, bank escrows are overseen by federal and state banking regulators. Attorney escrows may be reported to the State Bar. Identify the correct regulatory authority for your escrow holder.

Need Legal Help?

Escrow disputes can involve complex issues of fiduciary duty and agency law. Get a 30-minute strategy call with an attorney to evaluate your case and discuss next steps.

Book Consultation - $125

California Resources

  • DFPI (Dept. of Financial Protection): dfpi.ca.gov - File complaints, verify escrow licenses
  • California DRE: dre.ca.gov - For broker-operated escrows
  • California Financial Code: leginfo.legislature.ca.gov - Full text of Escrow Law (17000+)
  • Small Claims Court: courts.ca.gov/selfhelp-smallclaims.htm
  • State Bar Lawyer Referral: calbar.ca.gov
  • CFPB: consumerfinance.gov - For complaints about RESPA/closing disclosure violations