One of our counties recently went through a map revision. Most of the loans that were affected were older loans and we had not set up an escrow account for those customers. Are we required to go back and start escrowing for those customers even though we are not currently escrowing for them? Also, we had two that were currently escrowing for home owners insurance and property taxes. Will we be required to go back and add the flood insurance to their escrow accounts even though it was added to the loan after the loan closed?
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.
I haven’t been following the flood escrow changes very closely. I keep finding lots of updates and pieces of information. Is there one place I can find all of the requirements of flood escrow for 2016?