[Sandy]

We have had flood map revisions in our area. We have 2 properties that are now in a flood zone. One has about 4 barns on a very large farm. We have abundance of collateral and the loan officer may do a mortgage release on that tract. If the borrower never carries flood insurance do we have to make sure we had carried forced place flood insurance from the date of the determination until we do the mortgage release if we release it before the 45 days are up?

The other property is a residential property that has an older shed that has NCV. We thought about using the detached structure exemption. Same question. If the borrower does not carry flood insurance do we have to make sure we carry forced place flood insurance from date of determination until the date they singed the exemption form and that it is signed before the 45 days are up?

Topic

[Kimberly Boatwright, CAMS, CRCM]

1. Yes, if you are notified that the flood maps have been updated you are required to notify the borrower that the flood maps have been updated they need to get insurance. If they do not obtain it then you are required to forceplace it. At the time property it is released you would then need to follow the proper requirements to remove the insurance.

2. Yes, if there is any building in a flood plain regardless of use or condition it will require flood insurance per the regulations. As with the prior answer you are required to required to notify the borrower that the flood maps have been updated they need to get insurance. If they do not obtain it then you are required to forceplace it.

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