The Biggert-Waters escrow provisions are delayed until January 1, 2016 so currently there isn’t a requirement to escrow for flood insurance unless you are requiring escrow for other fees on a specific loan (i.e. if you require escrow for other fees on a loan that requires flood insurance you need to escrow for the flood insurance as well). For those loans which you currently require escrow, you will need to escrow for the flood insurance as well.
