Int Q&A – Escrow Small Lender Exception 1 – Is the $1B small lender exception for the mandatory escrow of flood insurance premiums at the lending institution level or bank holding company level?

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Q:  Escrow Small Lender Exception 1 – Is the $1B small lender exception for the mandatory escrow of flood insurance premiums at the lending institution level or bank holding company level?
 
A:   By its own terms, the small lender exception to the flood insurance escrow requirement applies to lenders rather than holding companies. Therefore, the $1 billion requirement is calculated based on the assets held at the lending institution level, rather than at the holding company level.
 
 
ADDITIONAL INFORMATION:
This Q&A was included in the Interagency Questions and Answers Regarding Flood Insurance, which were issued on 05/11/2022.  They were published in the Federal Register on 05/31/2022 and may be found here:  https://www.federalregister.gov/documents/2022/05/31/2022-10414/loans-in-areas-having-special-flood-hazards-interagency-questions-and-answers-regarding-flood
 

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