[Lisaw]

I need input from the group regarding ordering flood determinations. It has been our practice to order the determination when the LE package is ordered. During a recent training, it was mentioned that determinations should not be done before the intent to proceed is confirmed with the borrower.
Reg.Z 1026.19 states that a creditor cannot impose any fee until the consumer has indicated an intent to proceed. What is the practice of others in the group?
Thank you,

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[kmeade]

Our practice is to order the flood determination after we receive the borrower’s intent to proceed. The only thing we order before receiving the borrower’s intent to proceed is the credit bureau. I hope this helps! 1026.19(e)(a)(i)(A)

[Author]

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