The flood regulations state:
Except as provided in paragraphs (a)(2) or (c) of this section, an FDIC-supervised institution, or a servicer acting on its behalf, shall require the escrow of all premiums and fees for any flood insurance required under § 339.3(a) for any designated loan secured by residential improved real estate or a mobile home that is made, increased, extended, or renewed on or after January 1, 2016, payable with the same frequency as payments on the designated loan are required to be made for the duration of the loan.
This is a great question and I don’t believe there is anything that specifically addresses it. In my opinion, if the loan did not experience a MIRE event on or after January 1, 2016 then you are not required to escrow flood insurance. However, if the loan were made, increased, renewed or extended after January 1, 2016 we do not believe you would have the option to cancel the escrow of flood insurance.