July 2015 Flood Final Rule – Can you clarify that the status of the loan as of the “outstanding” date should determine whether the lender must send the option-to-escrow notice?

Compliance > Lending > Flood > 2015 Flood Final Rule - Escrows
Q:   Can you clarify that the status of the loan as of the “outstanding” date should determine whether the lender must send the option-to-escrow notice?
 
A:  Yes. For example, if a loan outstanding as of January 1, 2016, is a subordinate lien loan excepted from the escrow requirement, then a lender that is not subject to the small lender exception need not provide the notice of the option to escrow even if the lien status for such loan could subsequently change.
 
 

See additional details in the July 2015 Final Rule on Loans in Areas Having Special Flood Hazards, here:  https://www.federalregister.gov/articles/2015/07/21/2015-15956/loans-in-areas-having-special-flood-hazards

Add Feedback