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Flood Insurance – Escrow Requirement

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  • February 12, 2019 at 2:34 pm EST #14511
    mfitzpatrick
    Participant

    If the bank offers, but doesn’t require escrow on Non HPML loans will we loose the small lender exception within the flood insurance rules? We currently escrow for HPML loans and have on occasion setup an escrow account for a NON HPML loan per the borrowers request. The third qualification states “Did not have a policy of consistently and uniformly requiring the deposit of taxes, insurance premiums, fees, or any other charges in a escrow account for any loans secured by residential improved real estate or a mobile home.” I’m wondering if “required” is the key word.

    February 13, 2019 at 10:53 am EST #14533
    rcooper
    Member

    Allowing voluntary escrows would not preclude you from meeting and utilizing the exemption.

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