Most banks I have talked to either already have escrow in place for their flood loans or are waiting until July 2014 to implement escrow on flood loans if they aren’t exempt from the requirement. Your bank may implement escrow for existing flood loans by having the borrowers sign an escrow agreement and sending them the initial escrow statement within 45 days of establishing the escrow account. However, there will likely be more guidance on this process as regulations are written so it may be prudent to wait and see what the regulations require.
