FDIC FAQs – If a bank meets the other requirements, is it still eligible for the small lender exemption if…

Compliance > Lending > Flood > FAQs
Q:  If a bank meets the other requirements, is it still eligible for the small lender exemption if…
 
A:    
 
a)…It offers escrows at the request of the borrower?  Yes
b)… It collects escrow funds at closing at the request of a third party and then transfers the escrow funds to the third party servicing the loan?  Yes
c)…It collects escrow funds at closing and services the loan? No
 
 
ADDITIONAL INFORMATION:
This Q&A was included in the FDIC’s Flood Insurance Videos, which were updated in 2016, which may be found here:   https://www.fdic.gov/news/news/financial/2016/fil16018.html
 

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