[Debra]

I don’t think you are required to have the borrower escrow for flood before the 1/1/16 date…unless I am missing something.

This is a cut from the FDIC letter on the flood changes:

Escrow: The final rule requires institutions to escrow premiums and fees for flood insurance required by Part 339 for certain designated loans that are made, increased, extended, or renewed on or after January 1, 2016. It requires lenders to offer and make available to consumers the option to escrow premiums and fees for certain loans outstanding as of January 1, 2016. The final rule also implements exemptions to the escrow requirement provided under the HFIAA.

I’ve attached the hyperlink to the FDIC Summary Letter below.

https://www.fdic.gov/news/news/financial/2015/fil15032.pdf

Just my 2 cents.

[Author]

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