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A question we received from a member:
In 2011, we required flood escrow. We are under 1 billion. Would we be exempt from flood escrow requirements on January 1, 2016. We did not require escrow for taxes and insurance in 2011, only flood insurance.
We have heard back from two of the agencies who issued this rule (FDIC and FRB). Both say this practice would preclude you from utilizing the small lender exception under the new flood rules.
They commented that the intent of the escrow portion of the new flood rules is to have as many creditors escrowing for flood insurance as possible.
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