FORUM PROFILE

Flood Escrow Exception

Tagged: ,

  • Creator
    Topic
  • July 9, 2015 at 2:45 pm EDT #7140
    rcooper
    Member

    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.

  • Creator
    Topic
Viewing 1 replies (of 1 total)
  • Author
    Replies
  • July 20, 2015 at 2:54 pm EDT #7158
    rcooper
    Member

    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.

  • Author
    Replies
Viewing 1 replies (of 1 total)
  • You must be logged in to reply to this topic.